Tax Planning Strategies for Derivative Financial Products
Leveraging Tax Benefits From Emerging IRS Guidance
Recording of a 90-minute CLE/CPE webinar with Q&A
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.
- 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
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)?
Matthew A. Stevens
He specializes in the design, structuring and implementation of financial transactions, including preferred stock... | Read More
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.Close
She recently joined the firm in its tax and financial services groups. She previously worked in the Office of Tax... | Read More
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.Close
Geoffrey B. Lanning
His practice focuses on taxation of corporations and corporate reorganizations, subchapter S corporations, financial... | Read More
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.Close
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