Description
This program recording provides detailed discussion on two separate topics:
1. Downturn Tax Issues, which covers the tax consequences to debtors and their creditors of debt restructuring and other workouts, including questions and opportunities raised by new section 108(i), and whether foreign creditors may become subject to U.S. tax on net income by reason of the workout activities of portfolio managers and mortgage servicers in the United States.
Speakers
David S. Miller, Esq. (Chair)
Cadwalader, Wickersham & Taft LLP
New York City
John Harrell, Esq.
Senior Counsel
Office of International Tax Counsel
Department of the Treasury
Washington, D.C.
David H. Schnabel, Esq.
Debevoise & Plimpton LLP
New York City
Linda Z. Swartz, Esq.
Cadwalader, Wickersham & Taft LLP
New York City
Jeffrey Van Hove, Esq.
Deputy Tax Legislative Counsel
(Tax Regulation)
Department of the Treasury
Washington, D.C.
2. Transactions: Form, Substance, and Understanding the Limits which surveys recent private letter rulings and various transaction structures, analyzes what determines when the form of a transaction should be respected, examines trends in transactional electivity, and discusses the impact of recent case law and potential codification of economic substance on the characterization of transactions.
Speakers
Karen Gilbreath-Sowell, Esq.(Chair)
Ernst & Young LLP
Washington, D.C.
William D. Alexander, Esq.
Associate Chief Counsel (Corporate)
Internal Revenue Service
Washington, D.C.
Kimberly S. Blanchard, Esq.
Weil, Gotshal & Manges LLP
New York City
Michael A. DiFronzo, Esq.
Deputy Associate Chief Counsel
(International-Technical)
Internal Revenue Service
Washington, D.C.
Gordon E. Warnke, Esq.
Dewey & LeBoeuf LLP
New York City
Total MCLE Credits 3.0
Ethics MCLE Credits0.0
* Each additional person who uses the tapes for MCLE credit must purchase a copy of the “MCLE coursebook.”
The product type below that starts with the letter 'V' is a video online program that you will view and listen to on your computer screen. The program code for each topic that you write on the included MCLE Form only appears on the screen and is not announced by audio.