Why you should attend
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. At 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.
What you will learn
- All you need to know about the tax issues arising out of hedges of transactions in nonfunctional currency
- The major differences between the proposed regulations governing noncompensatory options over partnership interests and the (anticipated) final regulations, as well as some insights into planning opportunities that may exist
- How the tough issues raised by the proposed regulations under section 871(m) were resolved in the (anticipated) final regulations
- How to recognize and deal with financial transactions that arise in mergers and acquisitions transactions
- Important tax planning issues for hedge and private equity fund managers
- Tax issues arising in the structuring of investment in master limited partnership interests, including derivative investments
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.
Morning Session: 9:00 a.m. - 12:30 p.m.
9:00 Introduction and Opening Remarks
Matthew A. Stevens
9:15 Tax Planning for Hedge Fund Managers
- Structuring opportunities for fund managers
- Cross-border issues
- State and local tax issues
- Carried interest update
Dominique Padilla Gallego, John C. Hart, Yoram Keinan
10:15 Selected Tax Issues Affecting Hedge Funds
- Notional principal contracts and other derivatives over MLPs
- Issues surrounding loan originations and loan modifications
- Distressed debt accounting
- Planning associated with the new Medicare Contribution Tax
Stuart E. Leblang, Jeffrey W. Maddrey, Mark S. Perwien
11:15 Networking Break
11:30 Final Regulations under Section 871(m)
- Issues under the proposed regulations
- Government attorneys’ latest thinking
- Discussion of final regulations (if released)
Jesse F. Eggert, Julio M. Jimenez, D. Peter Merkel, Laurence Salva, Matthew A. Stevens
Afternoon Session: 1:45 p.m. - 5:00 p.m.
1:45 Noncompensatory Partnership Options
- Unresolved issues under the proposed regulations
- Traps for the unwary
- Planning opportunities
Jennifer H. Alexander, Pamela Lawrence Endreny, Eric B. Sloan, Joy C. Spies
2:45 Foreign Exchange Hedging Issues
- Business reasons for hedging intercompany debt
- Hedges of debt of a disregarded entity
- Bad things that can happen without hedge treatment
Douglas E. Chestnut, Viva Hammer, L.G. “Chip” Harter, Brian H. Jenn
3:45 Networking Break
4:00 Financial Products Issues in Mergers and Acquisitions
- Using derivatives to transfer burdens and benefits of ownership
- Significant modifications of debt
- Withholding tax issues
Linda E. Carlisle, Eileen Marshall, Po Sit, Claude B. Stansbury
Jennifer H. Alexander
~ Former Attorney Advisor (Office of Tax Legislative Counsel) Department of the Treasury, Deloitte Tax LLP
Brian H. Jenn
~ Attorney Advisor (Tax Policy), U.S. Department of the Treasury
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
~ Davis Polk & Wardwell LLP
Joy C. Spies
~ Senior Technician Reviewer, Office of Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
New York City Seminar Location
PLI New York Center, 810 Seventh Avenue at 53rd Street (21st floor), New York, New York 10019. Message Center, program days only: (212) 824-5733.
New York City Hotel Accommodations
The New York Hilton & Towers
1335 Avenue of the Americas, New York, NY 10019. 1 block from PLI Center. Reservations 1-800-HILTONS or, 1-877-NYC-HILT. Please mention that you are booking a room under the Practising Law Institute Corporate rate and the Client File # is 0495741. You can also make reservations
online to access Practising Law Institute rates.
The Warwick New York Hotel, 65 West 54th Street New York, NY 10019. 1 block from PLI Center. Reservations 800-223-4099 or, hotel direct 212-247-2700. Please mention that you are booking a room under the Practising Law Institute Corporate rate. Reservations on line at www.warwickhotelny.com Click reservations in menu bar on left. Select desired dates. In 'Special Rates' drop down window select Corporate Rate. In 'Rate Code' enter PLIN. Click search and select desired room type and rate plan. Or, you may email reservation requests to: firstname.lastname@example.org
Sheraton New York Hotel & Towers
, 811 7th Avenue, New York, NY 10019, 1-800-325-3535 or (212) 581-1000. When calling, please mention Practising Law Institute and mention SET#311155. You may also book online
PLI's live programs are approved in all states that require mandatory continuing legal education for attorneys, except Arizona. Please be sure to check with your state 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.
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.