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Taxation of Financial Products and Transactions 2013

Released on: Jan. 30, 2013

Running Time: 06:09:27

Segments
Overview
Faculty
CLE Credit

Running Time	Segment Title	Faculty
[01:06:48]	Tax Planning for Hedge Fund Managers	Dominique Padilla Gallego ~ Schulte Roth & Zabel LLP John C. Hart ~ Simpson Thacher Bartlett LLP Yoram Keinan ~ Greenberg Traurig, LLP
[00:57:27]	Selected Tax Issues Affecting Hedge Funds	Mark S. Perwien ~ Special Counsel to Associate Chief Counsel (Financial Institutions and Products), Internal Revenue Service Jeffrey W. Maddrey ~ PwC Stuart E. Leblang ~ Akin Gump Strauss Hauer & Feld LLP
[01:01:23]	Final Regulations under Section 871(m)	Julio M. Jimenez ~ Ernst & Young LLP D. Peter Merkel ~ Attorney-Advisor (International, Branch 5), Internal Revenue Service Laurence Salva ~ Managing Director, Citigroup Global Markets, Inc. Matthew A. Stevens ~ Ernst & Young LLP
[00:59:49]	Noncompensatory Partnership Options	Eric B. Sloan ~ Principal, Deloitte Tax LLP Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP Jennifer H. Alexander ~ Former Attorney Advisor (Office of Tax Legislative Counsel) Department of the Treasury, Deloitte Tax LLP Joy C. Spies ~ Senior Technician Reviewer, Office of Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
[01:01:34]	Foreign Exchange Hedging Issues	Douglas E. Chestnut ~ Ernst & Young LLP Viva Hammer ~ Brandeis University L. G. Chip Harter ~ PwC Brian H. Jenn ~ Attorney Advisor (Tax Policy), U.S. Department of the Treasury
[00:59:53]	Financial Products Issues in Mergers and Acquisitions	Linda E. Carlisle ~ White & Case LLP Po Sit ~ Davis Polk & Wardwell LLP Claude B. Stansbury ~ Freshfields Bruckhaus Deringer LLP Eileen Marshall ~ Wilson Sonsini Goodrich & Rosati, P.C.

With implementation of the Dodd-Frank Act well underway, and judicial and administrative scrutiny remaining at a high level, it is important to stay on top of the latest developments in the fast changing area of financial products and transactions. In this program, a standout group of law firm and accounting firm lawyers, in-house tax advisors, and government speakers will explore new and old topics in financial transactions.

Lecture Topics [Total time 06:09:27]

Segments with an asterisk (*) are available only with the purchase of the entire program.

Introduction and Opening Remarks* [00:02:33]
Matthew A. Stevens
Tax Planning for Hedge Fund Managers [01:06:48]
Dominique Padilla Gallego, John C. Hart, Yoram Keinan
Selected Tax Issues Affecting Hedge Funds [00:57:27]
Stuart E. Leblang, Jeffrey W. Maddrey, Mark S. Perwien
Final Regulations under Section 871(m) [01:01:23]
Matthew A. Stevens, D. Peter Merkel, Julio M. Jimenez, Laurence Salva
Noncompensatory Partnership Options [00:59:49]
Jennifer H. Alexander, Pamela Lawrence Endreny, Eric B. Sloan, Joy C. Spies
Foreign Exchange Hedging Issues [01:01:34]
Douglas E. Chestnut, Viva Hammer, L. G. Chip Harter, Brian H. Jenn
Financial Products Issues in Mergers and Acquisitions [00:59:53]
Linda E. Carlisle, Eileen Marshall, Po Sit, Claude B. Stansbury

The purchase price of this Web Program includes the following articles from the Course Handbook available online:

Section 457A and Collateralized Loan Obligations (CLOs)
Dominique Padilla Gallego
Self-Employment and Medicare Taxes
John C. Hart
Management Fee Waiver
Yoram Keinan
Tax Accounting for Credit Spreads: Credit Default Swaps and Revolving Credit Agreements
Jeffrey W. Maddrey
Considerations for Investment Management Professionals Associated with the Medicare Tax
Stuart E. Leblang
Withholding Tax on Dividend-Related Payments on Notional Principal Contracts and Other Equity-Linked Instruments: Where Are We Now?
Matthew A. Stevens
The Proposed Regulations on Noncompensatory Options
Matthew Sullivan
Section 1256 and Foreign Currency Derivatives: 30 Years of Uncertainty
Viva Hammer
Employee Benefits Plan
Linda E. Carlisle
Selected Financial Products Issues in Mergers and Acquisition Transactions
Linda E. Carlisle, Eileen Marshall, Po Sit
Selected Tax Issues Affecting Hedge Funds (PowerPoint Slides)
Stuart E. Leblang
Index to Taxation of Financial Products and Transactions 2013

Presentation Material

Section 457A and Collateralized Loan Obligations (CLOS)
Dominique Padilla Gallego
Management Fee Waiver
John C. Hart
Self-employment and Medicare Taxes
Yoram Keinan
Selected Tax Issues Affecting Hedge Funds
Stuart E. Leblang
Selected Tax Issues Relevant to Hedge Funds
Stuart E. Leblang, Jeffrey W. Maddrey
Section 871(m): The Withholding Agent’s Perspective and Other Issues
Matthew A. Stevens, D. Peter Merkel, Julio M. Jimenez, Laurence Salva
Taxation of Financial Products and Transactions 2013: Noncompensatory Partnership Options
Jennifer H. Alexander, Pamela Lawrence Endreny, Eric B. Sloan, Joy C. Spies
Current Foreign Currency Issues
Douglas E. Chestnut, Viva Hammer, L. G. Chip Harter, Brian H. Jenn
Financial Products Issues in M&A Transactions
Linda E. Carlisle, Eileen Marshall, Po Sit, Claude B. Stansbury
Selected Financial Products Issues in Mergers and Acquisition Transactions
Eileen Marshall

Chairperson(s)

Matthew A. Stevens ~ Ernst & Young LLP

Speaker(s)

Jennifer H. Alexander ~ Former Attorney Advisor (Office of Tax Legislative Counsel) Department of the Treasury, Deloitte Tax LLP

Linda E. Carlisle ~ White & Case LLP

Douglas E. Chestnut ~ Ernst & Young LLP

Pamela Lawrence Endreny ~ Skadden, Arps, Slate, Meagher & Flom LLP

Dominique Padilla Gallego ~ Schulte Roth & Zabel LLP

Viva Hammer ~ Brandeis University

John C. Hart ~ Simpson Thacher Bartlett LLP

L. G. Chip Harter ~ PwC

Brian H. Jenn ~ Attorney Advisor (Tax Policy), U.S. Department of the Treasury

Julio M. Jimenez ~ Ernst & Young LLP

Yoram Keinan ~ Greenberg Traurig, LLP

Stuart E. Leblang ~ Akin Gump Strauss Hauer & Feld LLP

Jeffrey W. Maddrey ~ PwC

Eileen Marshall ~ Wilson Sonsini Goodrich & Rosati, P.C.

D. Peter Merkel ~ Attorney-Advisor (International, Branch 5), Internal Revenue Service

Mark S. Perwien ~ Special Counsel to Associate Chief Counsel (Financial Institutions and Products), Internal Revenue Service

Laurence Salva ~ Managing Director, Citigroup Global Markets, Inc.

Po Sit ~ Davis Polk & Wardwell LLP

Eric B. Sloan ~ Principal, Deloitte Tax LLP

Joy C. Spies ~ Senior Technician Reviewer, Office of Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service

Claude B. Stansbury ~ Freshfields Bruckhaus Deringer LLP

PLI makes every effort to accredit its On-Demand Web Programs and Segments. Please check the CLE Calculator above for CLE information specific to your state.

On-Demand Web Programs and Segments are approved in:

Alabama¹, Alaska, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho*, Illinois , Iowa²*, Kansas, Kentucky*, Louisiana, Maine*, Mississippi, Missouri³, Montana, Nebraska, Nevada, New Hampshire⁴, New Jersey, New Mexico⁵, New York⁶, North Carolina⁸, North Dakota, Ohio⁸, Oklahoma⁹, Oregon*, Pennsylvania¹⁰, Rhode Island¹¹, South Carolina, Tennessee¹², Texas, Utah, Vermont, Virginia¹³, Washington, West Virginia, Wisconsin¹⁴ and Wyoming*.

Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.
Minnesota approves live webcasts ONLY

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

*PLI will apply for credit upon request. Louisiana and New Hampshire: PLI will apply for credit upon request for audio-only on-demand web programs.

¹Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.

²Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.

³Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.

⁴New Hamphsire: The approval is for three years from recorded date.

⁵New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.

⁶New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web 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.

⁷North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.

⁸Ohio: To confirm that the web program 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 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.

⁹Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.

¹⁰Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.

¹¹Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.

¹²Tennessee: The approval is for the calendar year in which the live program was presented.

¹³Virginia: All distance learning courses are to be done in an educational setting, free from distractions.

¹⁴Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.

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.

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.

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, call Customer Service (800) 260-4PLI (4754) or e-mail info@pli.edu.

Course Handbook Archive

Taxation of Financial Products and Transactions 2013	Matthew A. Stevens, Ernst & Young LLP
Taxation of Financial Products and Transactions 2012	Matthew A. Stevens, Ernst & Young LLP

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	On-Demand Segment Description Faculty CLE Credit PLI makes every effort to accredit its recorded programs. PLI MP3s are approved in the following states/territories: AK, CA¹, CO, FL, GA, ID, IL, KS², ME, MO, MT, NC, ND, NH, NJ, NM, NV, NY, OR, PA, TX³, UT, VI, VT, WA, WV, WY. Some exceptions apply. For more information contact PLI. ¹California: This activity qualifies for participatory credit. ²Kansas: There is a 5.0 credit limit per year for this type of viewing. ³Texas: Considered self-study credit. There is a 5 credit limit, including specialty credit. Please note:* The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. *PLI will apply for credit upon request. Running time and CLE credit hours earned are not necessarily the same. Please be aware that many states do not permit credit for luncheon speakers. Special Note: In New York, non-traditional course formats including audio and video cassettes are NOT acceptable for transitional CLE credit for the newly admitted attorney within the first two years after their admission to the Bar. Attorneys other than newly admitted may use non-traditional course format, including audio and video cassettes to fulfill their CLE requirements. IMPORTANT INFORMATION FOR ATTORNEYS SEEKING CLE CREDIT While listening to the program, be alert to listen for the AUTHORIZATION CODE which has been placed somewhere within the program. Write the code down; you will be asked for this information when you request CLE credit. Once you’ve completed the program, please go to www.pli.edu and log in. Once you are logged in, your account will be displayed and the available programs will be listed on the left side under the heading "My Online Library". If you are already logged in, click the link for My Account on the home page to access your Online Library. Return to the program and click the MCLE Registration button in the top right region of the program window. A new window will open with a CLE Request form, you will be asked to complete a short evaluation, and fill in the AUTHORIZATION CODE, please complete and submit the form. Once you click the Submit button, your request for CLE credit will be sent to the CLE department. PLI will email you a CLE certificate within 48 hours. If you are unable to successfully log in, please contact our customer service department at 800-260-4754 for assistance. GENERAL INFORMATION This product is designed to provide practical and useful information on the subject matter covered. However, it is sold with the understanding that the publisher is not engaged in rendering legal, accounting or other professional services. If legal advice or other expert assistance is required, the services of a competent professional should be sought. 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. PLI makes every effort to accredit its On-Demand Web Programs and Segments. Please check the CLE Calculator above for CLE information specific to your state. On-Demand Web Programs and Segments are approved in: Alabama¹, Alaska, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois , Iowa², Kansas, Kentucky, Louisiana, Maine, Mississippi, Missouri³, Montana, Nebraska, Nevada, New Hampshire⁴, New Jersey, New Mexico⁵, New York⁶, North Carolina⁸, North Dakota, Ohio⁸, Oklahoma⁹, Oregon, Pennsylvania¹⁰, Rhode Island¹¹, South Carolina, Tennessee¹², Texas, Utah, Vermont, Virginia¹³, Washington, West Virginia, Wisconsin¹⁴ and Wyoming. Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs. Minnesota approves live webcasts ONLY The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. *PLI will apply for credit upon request. Louisiana and New Hampshire: PLI will apply for credit upon request for audio-only on-demand web programs. ¹Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits. ²Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts. ³Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit. ⁴New Hamphsire: The approval is for three years from recorded date. ⁵New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year. ⁶New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web 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. ⁷North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs. ⁸Ohio: To confirm that the web program 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 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. ⁹Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs. ¹⁰Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour. ¹¹Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component. ¹²Tennessee: The approval is for the calendar year in which the live program was presented. ¹³Virginia: All distance learning courses are to be done in an educational setting, free from distractions. ¹⁴Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts. 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. 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. 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, call Customer Service (800) 260-4PLI (4754) or e-mail info@pli.edu. Add to Cart Membership Suite Options: Add to My List Register From Roster Request Groupcast Receive all of the items below at the reduced price of $0.00 A combined savings of $0.00 Buy Combo CREDIT INFORMATION Credits for: