Publications Memos Go Back IRS Confirms Treatment Of Equity Units; Permits Interest Deduction 07.28.03 This memorandum, by members of the Tax Department, addresses IRS Revenue Ruling 2003-97 dealing with the treatment of equity units. Authors and Contacts Marcy Geller Partner [email protected] +1-212-455-3543 Related Insights 01.20.26 | Publications Fifth Circuit Rules That Soroban Was Incorrectly Decided and SECA Tax Exception Applies to Limited Partners With Limited Liability Regardless of Activities 12.15.25 | Publications IRS Releases Final and Proposed Regulations Under Section 892 10.21.25 | Publications IRS Releases Proposed Regulations Under Section 897 on Domestically Controlled REITs Related Services Related Practice Areas Tax