The panel will discuss the federal income tax treatment of guaranteed payments for the use of capital, including the ExxonMobil Corp. v. U.S. briefing released to the public in July 2026, and when a guaranteed payment may instead be treated as a distributive share of partnership income. The discussion will also cover the Section 163(j) anti-avoidance rule, including when guaranteed payments may be treated as interest, and the implications for current M&A, private credit, and other partnership financing structures.