Tax Planning Strategies for Derivative Financial Products
Leveraging Tax Benefits From Emerging IRS Guidance
Recording of a 90-minute CLE teleconference with Q&A
Conducted on Tuesday, February 24, 2009
Recorded event now available
This seminar will examine emerging and settled tax issues in the area of derivatives. The seminar will focus on recent developments in tax law relating to these financial products with particular focus on nontraditional derivatives.
Description
The use of derivatives and other financial products are a mainstay in the financial markets. As the number and types of financial products grow and evolve, tax laws and regulations can't keep up with these developments. Too often, the current tax regime produces unanticipated results.
Different tax rules apply in different contexts, depending on the type of investor, income source, or transaction’s purpose. When new financial products are introduced, there are no clear rules for tax treatment and practitioners must try to fit these new products into exiting "cubbyholes."
Without clear guidance for tax advisors as to which category a particular transaction should fit in, there is ambiguity in structuring the transaction and applying the tax rules. Often, this cubbyhole approach leads to different tax treatment for transactions that are economically equivalent.
Listen as our authoritative panel of tax specialists discusses the various tax laws and regulations that apply to financial products and provide their insights and perspectives on the latest developments in financial product tax controversies.
Outline
- Approaches to Determine the Tax Treatment of New Financial Products
- Existing rules for traditional derivatives (options, forwards, future contracts, swaps)
- Market practice or cubbyhole approach for new financial products
- Unexpected or disparate tax consequences
- Current Tax Controversies for Nontraditional Derivatives
- Credit derivatives
- Prepaid forward contracts and exchange traded notes (ETNs)
- Variable prepaid forward contracts
Benefits
The panel will review these and other key questions:
- How can tax attorneys utilize the market practice approach to determine the tax treatment of new financial products?
- What are the latest tax controversies regarding credit derivatives?
- How is the IRS scrutinizing prepaid forward contracts, such as exchange traded notes (ETN)?
Faculty
Matthew A. Stevens,
Partner
Alston Bird, Washington, D.C.
He specializes in the design, structuring and implementation of financial transactions, including preferred stock financing transactions, swaps, options, debt instruments and forward contracts. He was counsel with the IRS advising on regulations, revenue rulings and notices involving convertible debt instruments, prepaid forward contracts, debt-forward contract units and notional contracts.
Viva Hammer,
Partner
Crowell Moring, New York
She recently joined the firm in its tax and financial services groups. She previously worked in the Office of Tax Policy in the Treasury Department where she was responsible for developing policy and law governing the taxation of financial institutions and products. She drafted and supervised the publication of the hedging regulations and notional principal contract (swap) regulations.
Geoffrey B. Lanning,
Attorney
White Case, Washington, D.C.
His practice focuses on taxation of corporations and corporate reorganizations, subchapter S corporations, financial derivative products, and legislative, regulatory, and administrative tax matters. He has years of government service with the Internal Revenue Service as an Attorney Advisor in the Office of the Chief Counsel and the U.S. Congress Joint Committee on Taxation.
Ordering
Online CLE - Audio Recording
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CLE: Pre-approved for self-study credit in: AK, AZ, CA, CT, HI, MO, MT, NY, TX*, VT, WA, WV. Upon request, self-study credit is also available in: CO, FL, GA, ID, KY, ME, ND, NE, NH, NM, NV, OR, UT, WI, WY. If you are applying for self-study credit in one of these states, contact Strafford CLE at 1-800-926-7926 ext. 35 or CLE@straffordpub.com. (*Indicates that Strafford needs to process the CLE — see below to purchase this option.)
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Customer Reviews
The seminar was given in a very user friendly presentation format.
Danielle Burns
Duane Morris LLP
The presenters were knowledgeable and able to intelligently answer questions.
Tommy Orr
Mikunda, Cottrell & Co., Inc.
It was a very good presentation of complex material, managed in an understandable format. The information will be useful in my practice.
Jay H. McDowell
Withers Bergman LLP
The speakers were excellent and made it easy to understand the complex subjects.
Michael Robinson
Winston & Strawn LLP
One of the best CLEs outside my firm that I have attended in a long time. The materials and the dual perspectives were great and the comments on one another's presentations were very instructive.
Lisa Taylor Hudson
Sands Anderson Marks & Miller
Tax Law Advisory Board
Tax Partner
Steptoe & Johnson
Of Counsel
Morrison & Foerster
Partner, Federal, State and International Tax Planning
Rogin Nassau
International Tax and Tax Controversies Partner
DLA Piper
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Transactional Tax Partner
McKenna Long & Aldridge
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Nixon Peabody
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Pepper Hamilton
Tax Controversy Partner
Crowell & Moring
Of Counsel
Skadden Arps
Peter Stathopoulos
Managing Director, State and Local Tax Practice
Bennett Thrasher
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
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