On January 13, 2010, Cravath partner Andrew W. Needham spoke at the “Taxation of Financial Instruments and Transactions Conference” in New York, sponsored by the Foundation for Accounting Education (FAE). Andy spoke on a panel entitled “Taxation of Debt” in which the question “Do the OID & Market Discount Rules Apply to Distressed Debt?” was discussed. The panel reviewed tax issues relating to investments in debt instruments, including the tax consequences relating to original issue discount and market discount; troubled debt instruments; debt exchanges and restructurings; and origination and restructuring activity under Section 864(b)(2).