6-Hour Program

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Overview

Why You Should Attend
Recent activity in both the executive and legislative branches of government has brought change to the financial products area. The proposed Section 385 regulations threaten traditional practices and transactions, while mark-to-market is once again on the horizon for a wide array of derivatives. Even where U.S. tax rules have not changed, the actions of foreign governments may make tax planning more difficult and many common financial transactions will raise puzzling issues. This year’s program has been completely redesigned to help you understand the latest changes to the landscape of the taxation of financial products and transactions, and provide new insight into familiar planning strategies.
 
What You Will Learn
• Analyze the impact of the Section 385 proposed regulations on financial products
• Explore the latest withholding tax issues, including contingent interest and commitment fees
• Examine interesting issues with swaps under current law: 
    o Multiple underlying assets
    o Wash sale/deemed exchange issues
    o Credit default swaps over a foreign currency denominated FX bond
• Hear our experts’ thoughts on when a derivative over an illiquid asset will be treated as an ownership interest
• Understand the implications of Senator Wyden’s legislative proposal to mark-to-market all derivatives
• Study the tax issues arising from guarantees in a variety of contexts

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 banks, and insurance companies; and government attorneys who want to stay on top of what’s happening in the capital markets will benefit from attending this program.

Credit Details