Matthew A. Stevens, Alston & Bird; Michael J. Desmond, Bingham McCutchen LLP; Richard G. Larkins, Ernst & Young LLP
The Practising Law Institute and the Pennsylvania Bar Institute present Taxation of Financial Products and Transactions on Tuesday, January 17, at the PBI CLE Conference Center in the Wanamaker Building in Philadelphia.
The seminar begins at 9:00 a.m. and ends at 5:00 p.m.
With implementation of the Dodd-Frank Act well underway and judicial and administrative scrutiny remaining at a high level, it is important for practitioners to stay on top of the latest developments in the fast-changing area of financial products and transactions. At this program, an outstanding group of law firm and accounting firm lawyers, in-house tax advisors, and government speakers will explore new topics in financial transactions and examine new angles on some of the familiar ones.
The faculty will explore the ways in which the IRS’s Large Business and International Division has stepped up to provide its own brand of informal tax guidance and identify the key tax issues clients will face under Dodd-Frank (including but not limited to issues arising under section 1256). The speakers will offer the latest theories on which strategies to reduce dividend withholding taxes will survive the enactment of section 871(m), and examine whether the contingent capital transactions used in Europe can produce Tier One capital with deductible payments in the United States.
A final feature will offer techniques for dealing with different financial transactions that have the same economic results but produce different tax consequences.
Among the speakers are Matthew A. Stevens, Alston & Bird LLP; Roland Barral, area counsel, Financial Services, Office of Chief Counsel, Internal Revenue Service; Richard G. Larkins, Ernst & Young LLP; Karl T. Walli, senior counsel, Financial Products, U.S. Department of Treasury.