Leveraged Partnership Transactions and Tax Opinions Since Canal Corp.
Structuring Transactions and Tax Advisor Engagements to Withstand IRS Scrutiny and Avoid Penalties
Recording of a 110-minute CLE/CPE webinar with Q&A
This teleconference will provide tax law advisors an analysis of the Canal Corp. decision, among others, on leveraged partnership transactions, discuss its troubling impact on tax opinion practice, and outline strategies for structuring partnership transactions and tax advisor engagements to withstand IRS scrutiny.
- Structuring leveraged partnership transactions
- Structuring loan guarantees and indemnities
- Impact on tax opinion practice
The panel will review these and other key questions:
- Will the Canal Corp. ruling significantly limit leveraged partnership transactions?
- How can counsel structure these transactions to withstand IRS scrutiny?
- Under what circumstances may a fixed fee or contingent fee arrangement render a tax opinion unreliable?
- When, if at all, should courts defer to the opinion of a reputable tax advisor in deciding whether to assess penalties against the taxpayer?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Jonathan M. Prokup
His practice encompasses a broad array of tax matters, from structuring complex financial transactions to representing... | Read More
His practice encompasses a broad array of tax matters, from structuring complex financial transactions to representing clients in tax controversies. He has particular expertise with transfer pricing and the tax consequences of cross-border financial transactions, including structuring and defense of sale-leaseback transactions, synthetic leases, repurchase agreements, and illiquid swap contracts.Close
Covington & Burling
His practice focuses on tax aspects of corporate and partnership transactions including mergers and acquisitions,... | Read More
His practice focuses on tax aspects of corporate and partnership transactions including mergers and acquisitions, private equity investments, public and private capital markets transactions, joint ventures and corporate restructurings. He advises private equity sponsors on fund formations and related matters as well as secondary purchasers of limited partnership interests in private equity funds.Close