1-Day Program

See Credit Details Below

Overview

The 2017 Tax Act substantially changed the landscape for many areas of tax practice, and the world of financial products is no exception. This year’s program has been completely re-designed to examine the parts of the Act that most closely affect financial products tax practitioners, including the new limitation on interest deductions under Section 163(j), the uncertain scope of Section 451(b), and the base erosion anti-abuse tax (the “BEAT”). We will also discuss familiar concepts that continue to be relevant in the post-2017  Tax Act world.
 
Topics Include
• The uncertain scope of book-tax conformity under new Section 451(b)
• The interest limitation of new Section 163(j)
• Financial products issues under global intangible low-taxed income (“GILTI”) 
• Financial transactions issues in mergers and acquisitions
• How to beat the BEAT (or at least not let it beat your client)
• The new anti-hybrid rules of Sections 245A and 267A

Program Level – Overview 

Intended Audience - Attorneys at law and accounting firms who advise clients on financial transactions and products; in-house tax professionals who help structure transactions and make ASC 740 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.

Prerequisites – Familiarity with the U.S. tax rules affecting financial products and transactions.

Advanced Preparation – None

Credit Details

Schedule & Location