This is a webcast of the live New York session.Why you should attend
As courts continue to surprise practitioners with rulings on financial products tax issues, and with implementation of the Dodd-Frank Act well underway, you need to stay on top of the latest developments in the ever-evolving arena of financial products and transactions. At this year’s completely revised program, a standout group of law firm and accounting firm lawyers, in-house tax advisors, and government speakers will explore new topics in financial transactions, and will shed new light on familiar topics.
What you will learn
- Transfer pricing for financial products experts
- Planning for bad debts
- Current issues under section 475
- What's new in the world of financial products tax controversies
- Tax reform for financial products - beyond Camp
- Financial products issues under section 987
Who should attend
Attorneys at law and accounting firms who advise clients on financial transactions and products; in-house tax professionals who help structure transactions and make FIN 48 determinations; hedge fund traders who want a better understanding of the tax rules governing financial products and transactions; accountants who work in the area of financial products; people who advise hedge fund managers and owners; and government attorneys who want to stay on top of what’s happening outside the government.
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.
All times are E.S.T.
Morning Session: 9:00 a.m. - 12:30 p.m. (E.S.T.)
9:00 Introduction and Opening Remarks
Matthew A. Stevens
NEW SESSION
9:15 Tax Reform for Financial Products: What to Think About Now
- The Camp and Obama Administration proposals
- Practitioner’s views
- Who wins and who loses
- Prospects for enactment
Richard G. Larkins, William Lu, Erika W. Nijenhuis, Karl Russo
NEW SESSION
10:15 Financial Products Issues Under Section 987
- What happens when the home office (HO) and a Section 987 qualified business unit (QBU) enter into a financial product
- Hedging of disregarded loans between the HO and the Section 987 QBU
- Hedging third party receivables held by the QBU
- Issues that arise when a Section 988 transaction is transferred to a QBU that has that currency as its functional currency
Douglas E. Chestnut, Jeffrey L. Dorfman, G. Garner Prillaman, Jr.
11:15 Networking Break
NEW SESSION
11:30 Planning for Bad Debts
- The debtor’s perspective
- The creditor’s perspective
- Related party loans
- Asset-backed securities
Lucy W. Farr, Helen M. Hubbard [Acting Associate Chief Counsel (Financial Institutions & Products) Internal Revenue Service], Matthew A. Stevens, Helen Yanchisin
12:30 Lunch
Afternoon Session: 1:45 p.m. - 5:00 p.m. (E.S.T.)
NEW SESSION
1:45 Hot Issues in Section 475
- Common traps resulting in security dealer status
- Practical considerations for commodities dealers and traders electing mark-to-market accounting
- Limited scope of Section 9100 relief granted for late elections
- IRS practice when taxpayers change from mark-to-market accounting
Alan B. Munro, William M. Paul, Jo Lynn Ricks, Robert B. Williams (invited) [Senior Counsel (Office of the Associate Chief Counsel, Financial Institutions and Products), Internal Revenue Service]
NEW SESSION
2:45 Tax Controversy in the Financial Products Arena
- How (and why) you need to educate judges on the complexity of financial transactions
- Do common law doctrines always trump taxpayers’ compliance with the code and regulations?
- How government litigators (and sometimes courts) misconstrue internal taxpayer communications
- Does government view most tax planning as shelter activity?
Joshua D. Odintz, Jean A. Pawlow, Alan J.J. Swirski, Gary B. Wilcox
3:45 Networking Break
NEW SESSION
4:00 Transfer Pricing in the Financial Products World
- How base erosion and profit sharing (BEPS) affects deemed permanent establishments
- The role of intangibles in the world of financial products transfer pricing
- The effect on transfer pricing of the increasing regulation of financial products
Kathryn H. O'Brien, Humberto M. Reboredo, Matthew A. Stevens
5:00 Adjourn
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, Indiana
1, Iowa*, Kansas*, Kentucky*, Louisiana, Maine*, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, New Hampshire*, New Jersey, New Mexico, Nevada, New York
2, Ohio
3, Oklahoma, Oregon*, Pennsylvania
4, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia
5, 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.