Seminar  Seminar

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2013


Select a Location:

This is a webcast of the live New York session.

Why you should attend

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. Evolving techniques for structuring, financing, and refinancing corporate turnovers and other activities will be emphasized, with particular attention being paid to consolidated return issues, to financially troubled businesses, to the role of new financial products and the effects of the evolving economic substance and business purpose doctrine, and to selected current issues in mergers and acquisitions, including the effects of recent legislation on executive compensation.

What you will learn

Major Topics & Special Features Include:
  • Tax accounting issues in mergers and acquisitions
  • Section 338(h)(10) strategies
  • Corporate tax strategies and techniques using partnerships and LLCs
  • Strategies for private equity
  • Structuring buyouts/venture capital deals
  • Current issues in tax-free and partially tax-free acquisitive reorganizations
  • Current issues in divisive strategies – spin-offs, split-offs and split-ups
  • Recent strategies for financially troubled businesses and other loss companies
  • “Cross-border” mergers and other international issues
  • Interesting corporate transactions of the past year
  • Issues and strategies in corporate financings and refinancings
  • Exploring the limits of the evolving economic substance and business purpose doctrines
  • Ethical and practice issues raised by recent tax shelter regulations and legislation and by Circular 230
  • Consolidated return planning and strategies under the new regulations

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Program Schedule To Come
Chairperson(s)
Louis S. Freeman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Speaker(s)
William D. Alexander ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Peter H. Blessing ~ KPMG LLP
Peter C. Canellos ~ Wachtell, Lipton, Rosen & Katz
Linda E. Carlisle ~ White & Case LLP
Audrey Nacamuli Charling ~ Senior Tax Counsel, General Electric Company
Stuart Chessman ~ Director, Taxes, Vivendi
Erik H. Corwin ~ Deputy Chief Counsel (Technical), Internal Revenue Service
Jasper L. Cummings, Jr. ~ Alston & Bird LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Peter L. Faber ~ McDermott Will & Emery LLP
Stephen P. Fattman ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Stuart M. Finkelstein ~ Skadden, Arps, Slate, Meagher & Flom LLP
James P. Fuller ~ Fenwick & West LLP
Stuart J. Goldring ~ Weil, Gotshal & Manges LLP
Armando Gomez ~ Skadden, Arps, Slate, Meagher & Flom LLP
Helen M. Hubbard(Invited) ~ Acting Associate Chief Counsel (Financial Institutions & Products), Internal Revenue Service, Room 3547
Tal Kaissar ~ Vice President & Director of Taxes, American International Group, Inc.
Bruce E. Kayle ~ Milbank, Tweed, Hadley & McCloy LLP
Kenneth E. Kempson ~ Senior Tax Counsel - Director of Tax Examination, General Electric Company
Kevin M. Keyes ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Jean M. McLoughlin ~ Davis Polk & Wardwell LLP
John J. Merrick ~ Special Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Branch Chief (Corporate, Branch 4), Internal Revenue Service
Scott Naatjes ~ Vice President, Tax and Customs, General Tax Counsel, Cargill, Incorporated
Robert J. Neis(invited) ~ Deputy Benefits Tax Counsel, U.S. Department of the Treasury
Jonathan R. Neuville ~ Linklaters
Erika W. Nijenhuis ~ Cleary Gottlieb Steen & Hamilton LLP
Regina Olshan ~ Skadden, Arps, Slate, Meagher & Flom LLP
Paul W. Oosterhuis ~ Skadden, Arps, Slate, Meagher & Flom LLP
Jeffrey H. Paravano ~ Baker & Hostetler LLP
Joseph M. Pari ~ KPMG LLP
Deborah L. Paul ~ Wachtell, Lipton, Rosen & Katz
Richard L. Reinhold ~ Willkie Farr & Gallagher LLP
Donald E. Rocap ~ Kirkland & Ellis LLP
Matthew A. Rosen ~ Skadden, Arps, Slate, Meagher & Flom LLP
Stuart L. Rosow ~ Proskauer
Blake D. Rubin ~ McDermott Will & Emery LLP
Michael L. Schler ~ Cravath, Swaine & Moore LLP
David H. Schnabel ~ Debevoise & Plimpton LLP
Mark A. Schneider ~ Deloitte Tax LLP
Michael L. Schultz ~ Bingham McCutchen LLP
Mark J. Silverman ~ Steptoe & Johnson LLP
Bryan C. Skarlatos ~ Kostelanetz & Fink LLP
Eric B. Sloan ~ Principal, Deloitte Tax LLP
Lewis R. Steinberg ~ Managing Director, Head of Strategic Advisory (Investment Banking Department), Credit Suisse Securities (USA) LLC
Linda Z. Swartz ~ Cadwalader, Wickersham & Taft LLP
Krishna P. Vallabhaneni(invited) ~ Attorney-Advisor (Tax Legislation); Office of Tax Policy, U.S. Department of the Treasury
Mark Weiss ~ Attorney, Office of Chief Counsel (Branch 6), Internal Revenue Service
Robert H. Wellen ~ Ivins, Phillips & Barker
Thomas F. Wessel ~ KPMG LLP
Robert Willens ~ President, Robert Willens, LLC
Lisa M. Zarlenga(invited) ~ Tax Legislative Counsel, U.S. Department of the Treasury
Isaac W. Zimbalist ~ Senior Technician Reviewer (Corporate Branch 5), Internal Revenue Service
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
PLI makes every effort to accredit its Live Webcasts. Please check the CLE Calculator above for CLE information specific to your state.

PLI's Live Webcasts are approved for MCLE credit (unless otherwise noted in the product description) in the following states/territories:  Alabama, Alaska, Arkansas, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois, Indiana1, Iowa*, Kansas*, Kentucky*, Louisiana, Maine*, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, New Hampshire*, New Jersey, New Mexico, Nevada, New York2, Ohio3, Oklahoma, Oregon*, Pennsylvania4, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia5, Virgin Islands, Washington, West Virginia, Wisconsin, and Wyoming*.

*PLI will apply for credit upon request.

Arizona: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement.

Arkansas and Oklahoma: Audio-only live webcasts are not approved for credit.

 

1Indiana: Considered a distance education course. There is a 6 credit limit per year.

2New York: Newly admitted attorneys may not take non-transitional course formats such as on-demand audio or video programs or live webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.

3Ohio: To confirm that the live webcast has been approved, please refer to the list of Ohio’s Approved Self Study Activities at http://www.sconet.state.oh.us. Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per biennial compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.

4 Pennsylvania: A live webcast may be viewed individually or in a group setting. Credit may be granted to an attorney who views a live webcast individually. There is a 4.0 credit limit per year for this type of viewing. A live webcast viewed in a group setting receives live participatory credit if the program is open to the public and advertised at least 30 days prior to the program. Live webcasts viewed in a group setting that do not advertise at least 30 days prior the program will be considered "in-house", and therefore denied credit.

5Virginia: All distance learning courses are to be done in an educational setting, free from distractions.


Running time and CLE credit hours are not necessarily the same. Please be aware that many states do not permit credit for luncheon and keynote speakers.

Note that some states limit the number of credit hours attorneys may claim for online CLE activities, and state rules vary with regard to whether online CLE activities qualify for participatory or self-study credits. For more information, refer to your state CLE website or call Customer Service at (800) 260-4PLI (4754) or email: info@pli.edu.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Why you should attend

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. Evolving techniques for structuring, financing, and refinancing corporate turnovers and other activities will be emphasized, with particular attention being paid to consolidated return issues, to financially troubled businesses, to the role of new financial products and the effects of the evolving economic substance and business purpose doctrine, and to selected current issues in mergers and acquisitions, including the effects of recent legislation on executive compensation.

What you will learn

Major Topics & Special Features Include:
  • Tax accounting issues in mergers and acquisitions
  • Section 338(h)(10) strategies
  • Corporate tax strategies and techniques using partnerships and LLCs
  • Strategies for private equity
  • Structuring buyouts/venture capital deals
  • Current issues in tax-free and partially tax-free acquisitive reorganizations
  • Current issues in divisive strategies – spin-offs, split-offs and split-ups
  • Recent strategies for financially troubled businesses and other loss companies
  • “Cross-border” mergers and other international issues
  • Interesting corporate transactions of the past year
  • Issues and strategies in corporate financings and refinancings
  • Exploring the limits of the evolving economic substance and business purpose doctrines
  • Ethical and practice issues raised by recent tax shelter regulations and legislation and by Circular 230
  • Consolidated return planning and strategies under the new regulations

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Program Schedule To Come
Chairperson(s)
Louis S. Freeman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Speaker(s)
William D. Alexander ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Kimberly S. Blanchard ~ Weil, Gotshal & Manges LLP
Peter H. Blessing ~ KPMG LLP
Peter C. Canellos ~ Wachtell, Lipton, Rosen & Katz
Linda E. Carlisle ~ White & Case LLP
Audrey Nacamuli Charling ~ Senior Tax Counsel, General Electric Company
Stuart Chessman ~ Director, Taxes, Vivendi
Erik H. Corwin ~ Deputy Chief Counsel (Technical), Internal Revenue Service
Jasper L. Cummings, Jr. ~ Alston & Bird LLP
William S. Dixon ~ Managing Director, Mergers & Acquisitions, Citigroup Global Markets Inc.
Peter L. Faber ~ McDermott Will & Emery LLP
Stephen P. Fattman ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Stuart M. Finkelstein ~ Skadden, Arps, Slate, Meagher & Flom LLP
James P. Fuller ~ Fenwick & West LLP
Stuart J. Goldring ~ Weil, Gotshal & Manges LLP
Armando Gomez ~ Skadden, Arps, Slate, Meagher & Flom LLP
Helen M. Hubbard(Invited) ~ Acting Associate Chief Counsel (Financial Institutions & Products), Internal Revenue Service, Room 3547
Tal Kaissar ~ Vice President & Director of Taxes, American International Group, Inc.
Bruce E. Kayle ~ Milbank, Tweed, Hadley & McCloy LLP
Kenneth E. Kempson ~ Senior Tax Counsel - Director of Tax Examination, General Electric Company
Kevin M. Keyes ~ Fried, Frank, Harris, Shriver & Jacobson LLP
Jean M. McLoughlin ~ Davis Polk & Wardwell LLP
John J. Merrick ~ Special Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Marie C. Milnes-Vasquez ~ Branch Chief (Corporate, Branch 4), Internal Revenue Service
Scott Naatjes ~ Vice President, Tax and Customs, General Tax Counsel, Cargill, Incorporated
Robert J. Neis(invited) ~ Deputy Benefits Tax Counsel, U.S. Department of the Treasury
Jonathan R. Neuville ~ Linklaters
Erika W. Nijenhuis ~ Cleary Gottlieb Steen & Hamilton LLP
Regina Olshan ~ Skadden, Arps, Slate, Meagher & Flom LLP
Paul W. Oosterhuis ~ Skadden, Arps, Slate, Meagher & Flom LLP
Jeffrey H. Paravano ~ Baker & Hostetler LLP
Joseph M. Pari ~ KPMG LLP
Deborah L. Paul ~ Wachtell, Lipton, Rosen & Katz
Richard L. Reinhold ~ Willkie Farr & Gallagher LLP
Donald E. Rocap ~ Kirkland & Ellis LLP
Matthew A. Rosen ~ Skadden, Arps, Slate, Meagher & Flom LLP
Stuart L. Rosow ~ Proskauer
Blake D. Rubin ~ McDermott Will & Emery LLP
Michael L. Schler ~ Cravath, Swaine & Moore LLP
David H. Schnabel ~ Debevoise & Plimpton LLP
Mark A. Schneider ~ Deloitte Tax LLP
Michael L. Schultz ~ Bingham McCutchen LLP
Mark J. Silverman ~ Steptoe & Johnson LLP
Bryan C. Skarlatos ~ Kostelanetz & Fink LLP
Eric B. Sloan ~ Principal, Deloitte Tax LLP
Lewis R. Steinberg ~ Managing Director, Head of Strategic Advisory (Investment Banking Department), Credit Suisse Securities (USA) LLC
Linda Z. Swartz ~ Cadwalader, Wickersham & Taft LLP
Krishna P. Vallabhaneni(invited) ~ Attorney-Advisor (Tax Legislation); Office of Tax Policy, U.S. Department of the Treasury
Mark Weiss ~ Attorney, Office of Chief Counsel (Branch 6), Internal Revenue Service
Robert H. Wellen ~ Ivins, Phillips & Barker
Thomas F. Wessel ~ KPMG LLP
Robert Willens ~ President, Robert Willens, LLC
Lisa M. Zarlenga(invited) ~ Tax Legislative Counsel, U.S. Department of the Treasury
Isaac W. Zimbalist ~ Senior Technician Reviewer (Corporate Branch 5), Internal Revenue Service
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute

New York Seminar Location & Hotel Accommodations

Crowne Plaza Times Square Manhattan, 1605 Broadway (at 48th Street), New York, New York 10019. (212) 977-4000. Please contact the hotel reservations department directly at 1-888-233-9527. When calling, please mention PLI-Tax Strategies to receive the preferred rate.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.

Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Why you should attend

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. Evolving techniques for structuring, financing, and refinancing corporate turnovers and other activities will be emphasized, with particular attention being paid to consolidated return issues, to financially troubled businesses, to the role of new financial products and the effects of the evolving economic substance and business purpose doctrine, and to selected current issues in mergers and acquisitions, including the effects of recent legislation on executive compensation.

What you will learn

Major Topics & Special Features Include:
  • Tax accounting issues in mergers and acquisitions
  • Section 338(h)(10) strategies
  • Corporate tax strategies and techniques using partnerships and LLCs
  • Strategies for private equity
  • Structuring buyouts/venture capital deals
  • Current issues in tax-free and partially tax-free acquisitive reorganizations
  • Current issues in divisive strategies – spin-offs, split-offs and split-ups
  • Recent strategies for financially troubled businesses and other loss companies
  • “Cross-border” mergers and other international issues
  • Interesting corporate transactions of the past year
  • Issues and strategies in corporate financings and refinancings
  • Exploring the limits of the evolving economic substance and business purpose doctrines
  • Ethical and practice issues raised by recent tax shelter regulations and legislation and by Circular 230
  • Consolidated return planning and strategies under the new regulations

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Program Schedule To Come
Chairperson(s)
Louis S. Freeman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Speaker(s)
Suresh T. Advani ~ Sidley Austin LLP
William D. Alexander ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Joan C. Arnold ~ Pepper Hamilton LLP
Lawrence M. Axelrod ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
James R. Barry ~ Mayer Brown LLP
Rick Bodnum ~ Managing Director, Corporate Tax, CME Group
Merwin M. Brandon III ~ Director, International & Domestic Tax Planning Analysis, Ball Corporation
Jody J. Brewster ~ Skadden, Arps, Slate, Meagher & Flom LLP
Linda E. Carlisle ~ White & Case LLP
William G. Cavanagh ~ Chadbourne & Parke LLP
Bryan P. Collins ~ Deloitte Tax LLP
Jasper L. Cummings, Jr. ~ Alston & Bird LLP
Diana S. Doyle ~ Latham & Watkins LLP
Peter L. Faber ~ McDermott Will & Emery LLP
Kathleen L. Ferrell ~ Davis Polk & Wardwell LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
David L. Forst ~ Fenwick & West LLP
Philip D. Gregorcy ~ Vice President - Corporate Tax, Mondelez International, Inc.
Mark R. Hoffenberg ~ KPMG LLP
Helen M. Hubbard(Invited) ~ Acting Associate Chief Counsel (Financial Institutions & Products), Internal Revenue Service, Room 3547
Jack S. Levin ~ Kirkland & Ellis LLP
Richard M. Lipton ~ Baker & McKenzie LLP
James M. Lynch ~ Winston & Strawn LLP
David J. Mangefrida ~ Senior Vice President/Director of Tax, Calamos Investments
Todd F. Maynes ~ Kirkland & Ellis LLP
William L. McRae ~ Cleary Gottlieb Steen & Hamilton LLP
John J. Merrick ~ Special Counsel to the Associate Chief Counsel (International), Internal Revenue Service
Robert J. Neis(invited) ~ Deputy Benefits Tax Counsel, U.S. Department of the Treasury
John B. Palmer, III ~ Foley & Lardner LLP
Candace A. Ridgway ~ Jones Day
David M. Rievman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Stephen D. Rose ~ Munger, Tolles & Olson LLP
Steven M. Rosenthal ~ Urban-Brookings Tax Policy Center
Michael L. Schler ~ Cravath, Swaine & Moore LLP
David H. Schnabel ~ Debevoise & Plimpton LLP
Erica Schohn ~ Skadden, Arps, Slate, Meagher & Flom LLP
Michael L. Schultz ~ Bingham McCutchen LLP
Eric B. Sensenbrenner ~ Skadden, Arps, Slate, Meagher & Flom LLP
Jeffrey T. Sheffield ~ Kirkland & Ellis LLP
Dean S. Shulman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Mark J. Silverman ~ Steptoe & Johnson LLP
Eric B. Sloan ~ Principal, Deloitte Tax LLP
Lewis R. Steinberg ~ Managing Director, Head of Strategic Advisory (Investment Banking Department), Credit Suisse Securities (USA) LLC
Bernita L. Thigpen ~ KPMG LLP
Krishna P. Vallabhaneni(invited) ~ Attorney-Advisor (Tax Legislation); Office of Tax Policy, U.S. Department of the Treasury
W. Kirk Wallace ~ Skadden, Arps, Slate, Meagher & Flom LLP
Gordon E. Warnke ~ Linklaters LLP
Mark Weiss ~ Attorney, Office of Chief Counsel (Branch 6), Internal Revenue Service
Thomas F. Wessel ~ KPMG LLP
Lawrence I. Witdorchic ~ Paul, Weiss, Rifkind, Wharton & Garrison LLP
Lowell D. Yoder ~ McDermott Will & Emery LLP
Lisa M. Zarlenga(invited) ~ Tax Legislative Counsel, U.S. Department of the Treasury
Isaac W. Zimbalist ~ Senior Technician Reviewer (Corporate Branch 5), Internal Revenue Service
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
Chicago Seminar Location and Hotel Accommodations

InterContinental Chicago Hotel, 505 North Michigan Avenue, Chicago, IL 60611. Telephone: 312-944-4100.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.

Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

Why you should attend

This three-day program will focus on the tax issues presented by the entire spectrum of modern major corporate transactions, from relatively simple single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. Evolving techniques for structuring, financing, and refinancing corporate turnovers and other activities will be emphasized, with particular attention being paid to consolidated return issues, to financially troubled businesses, to the role of new financial products and the effects of the evolving economic substance and business purpose doctrine, and to selected current issues in mergers and acquisitions, including the effects of recent legislation on executive compensation.

What you will learn

Major Topics & Special Features Include:
  • Tax accounting issues in mergers and acquisitions
  • Section 338(h)(10) strategies
  • Corporate tax strategies and techniques using partnerships and LLCs
  • Strategies for private equity
  • Structuring buyouts/venture capital deals
  • Current issues in tax-free and partially tax-free acquisitive reorganizations
  • Current issues in divisive strategies – spin-offs, split-offs and split-ups
  • Recent strategies for financially troubled businesses and other loss companies
  • “Cross-border” mergers and other international issues
  • Interesting corporate transactions of the past year
  • Issues and strategies in corporate financings and refinancings
  • Exploring the limits of the evolving economic substance and business purpose doctrines
  • Ethical and practice issues raised by recent tax shelter regulations and legislation and by Circular 230
  • Consolidated return planning and strategies under the new regulations

PLI Group Discounts

Groups of 4-14 from the same organization, all registering at the same time, for a PLI program scheduled for presentation at the same site, are entitled to receive a group discount. For further discount information, please contact membership@pli.edu or call (800) 260-4PLI.

PLI Can Arrange Group Viewing to Your Firm

Contact the Groupcasts Department via email at groupcasts@pli.edu for more details.

Cancellations

All cancellations received 3 business days prior to the program will be refunded 100%. If you do not cancel within the allotted time period, payment is due in full. You may substitute another individual to attend the program at any time.

Program Schedule To Come
Chairperson(s)
Louis S. Freeman ~ Skadden, Arps, Slate, Meagher & Flom LLP
Speaker(s)
William D. Alexander ~ Associate Chief Counsel (Corporate), Internal Revenue Service
Lawrence M. Axelrod ~ Special Counsel to the Associate Chief Counsel (Corporate), Internal Revenue Service
Jody J. Brewster ~ Skadden, Arps, Slate, Meagher & Flom LLP
Alison G. Burns ~ Deputy Associate Chief Counsel (Corporate), Internal Revenue Service
Linda E. Carlisle ~ White & Case LLP
John J. Clair ~ Latham & Watkins LLP
Nicholas J. DeNovio ~ Latham & Watkins LLP
Peter L. Faber ~ McDermott Will & Emery LLP
Gerald B. Fleming ~ Senior Technician Reviewer (Corporate, Branch 2), Internal Revenue Service
James P. Fuller ~ Fenwick & West LLP
Lisa A. Fuller ~ Branch Chief (Corporate, Branch 5), Internal Revenue Service
Arthur E. Galan ~ Managing Director, Oaktree Capital Management, LLC
Stephen L. Gordon ~ Cravath, Swaine & Moore LLP
B. Benjamin Haas ~ Director, Federal Tax Research & Planning Group, Exelon Corporpation
Viva Hammer ~ Brandeis University
Hal Hicks ~ Skadden, Arps, Slate, Meagher & Flom LLP
Helen M. Hubbard(Invited) ~ Acting Associate Chief Counsel (Financial Institutions & Products), Internal Revenue Service, Room 3547
Thomas A. Humphreys ~ Morrison & Foerster LLP
Milton B. Hyman ~ Irell & Manella LLP
Mark A. Jewett ~ Tax Director, Amazon.com Inc.
Rachel D. Kleinberg ~ Davis Polk & Wardwell LLP
Donald L. Korb ~ Sullivan & Cromwell LLP
Don A. Leatherman ~ W. Allen Separk Distinguished Professor of Law, University of Tennessee College of Law
Philip J. Levine ~ McDermott Will & Emery LLP
Richard M. Lipton ~ Baker & McKenzie LLP
James M. Lynch ~ Winston & Strawn LLP
Steven A. Musher ~ Associate Chief Counsel (International), Internal Revenue Service
Robert J. Neis(invited) ~ Deputy Benefits Tax Counsel, U.S. Department of the Treasury
Victor L. Penico ~ Deloitte Tax LLP
Clarissa C. Potter ~ Deputy Director of Taxes, Head of Global Tax Strategy, American Internation Group (AIG), Tax Department
Stephen D. Rose ~ Munger, Tolles & Olson LLP
Diane S. Ryan ~ Skadden, Arps, Slate, Meagher & Flom LLP
Michael L. Schler ~ Cravath, Swaine & Moore LLP
David H. Schnabel ~ Debevoise & Plimpton LLP
Jodi J. Schwartz ~ Wachtell, Lipton, Rosen & Katz
Mark J. Silverman ~ Steptoe & Johnson LLP
Eric B. Sloan ~ Principal, Deloitte Tax LLP
Lewis R. Steinberg ~ Managing Director, Head of Strategic Advisory (Investment Banking Department), Credit Suisse Securities (USA) LLC
Raj Tanden ~ BuchalterNemer, A Professional Corporation
Samuel C. Thompson, Jr. ~ Arthur Weiss Distinguished Faculty Scholar, Director Center for the Study of M&A, Penn State Dickinson School of Law
Krishna P. Vallabhaneni(invited) ~ Attorney-Advisor (Tax Legislation); Office of Tax Policy, U.S. Department of the Treasury
Jeffrey L. Vogel ~ KPMG LLP
Gordon E. Warnke ~ Linklaters LLP
Mark Weiss ~ Attorney, Office of Chief Counsel (Branch 6), Internal Revenue Service
Stephen E. Wells ~ McDermott Will & Emery LLP
Thomas F. Wessel ~ KPMG LLP
Andrea Macintosh Whiteway ~ McDermott Will & Emery LLP
Philip B. Wright ~ Bryan Cave LLP
Joseph M. Yaffe ~ Skadden, Arps, Slate, Meagher & Flom LLP
Program Attorney(s)
Stacey L. Greenblatt ~ Practising Law Institute
Los Angeles Seminar Location and Hotel Accommodations

Intercontinental Los Angeles Century City, 2151 Avenue of the Stars, Los Angeles, California 90067. Tel: 1-310-284-6500. Fax: 1-310-284-6501.

PLI programs qualify for credit in all states that require mandatory continuing legal education for attorneys. Please be sure to check with your state and the credit calculator to the right for details.


Please check the CLE Calculator above each product description for CLE information specific to your state.

Special Note: In New York, newly admitted attorneys may receive CLE credit only for attendance at "transitional" programs during their first two years of admission to the Bar. Non-traditional course formats such as on-demand web programs or recorded items, are not acceptable for CLE credit. Experienced attorneys may choose to attend and receive CLE credit for either a transitional course or for one geared to experienced attorneys.  All product types, including on-demand web programs and recorded items, are approved for experienced attorneys.

Please Note: The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. PLI programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

Credit will be granted only to the individual on record as the purchaser unless alternative arrangements (prearranged groupcast) are made in advance.

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