Andrey Krahmal (Cahill Gordon & Reindel, New York) has posted Hybrid Instruments: Jurisdiction Dependent Characteristics, 5 Hous. Bus. & Tax J. 1 (2005), on SSRN.  Here is the abstract:

The article discusses a recent proliferation of the hybrid financial instruments and strives to aid the tax practitioner in understanding the analytical framework underlying such instruments, which often raise heightened attention of the revenue authorities in various jurisdictions and are sometimes thought to be problematic from the tax compliance point of view. The article reaches a conclusion that the current legal framework does not prohibit hybrid instruments per se and argues that most of such transactions are not abusive.