Jennifer H. Alexander, frmr atty advisor, Office of Tax Legislative Counsel, U.S. Department of the Treasury; William P. Bowers, Fulbright & Jaworski LLP; Richard J. Bronstein, Paul, Weiss, Rifkind, Wharton & Garrison LLP
This seminar will trace the partnership tax rules from the birth of the partnership through its operating life, with emphasis on tax issues and planning strategies and opportunities; then it will focus on exit strategies and tax planning possibilities in unwinding. Some sessions on day one will review basics. Special attention will be given to planning under recently finalized sets of regulations and proposed regulations and to changes wrought by recent legislation and legislative proposals. Speakers from Treasury and the IRS on the advanced panels will discuss cutting-edge issues. The afternoon of the third day cover international joint venture tax planning including the use of hybrids.