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.
Slides |
Downturn Tax Issues | Available after Purchase |
Materials |
Tax Section Annual Meeting 2010 Program Coursebook Cover | Available after Purchase |
Downturn Tax Issues - PowerPoint Slides | Available after Purchase |
Tax Report 1182 - NYSBA Tax Section Report on the Cancellation of Indebtedness | Available after Purchase |
Tax Report 1163 | Available after Purchase |
Select Case Law Related to Characterizing Transactions by Karen Gilbreath-Sowell | Available after Purchase |
Tax Report 1032 - NYSBA Tax Section Summary Report on the Provisions of Recent Senate Bills that Would Codify the Economic Substance Doctrine | Available after Purchase |
Transactions - Form, Substance, and Understanding the Limits by Kimberly Blanchard | Available after Purchase |
Tax Section Report 1032 Examples | Available after Purchase |
Multiple Step Acquisitions - Dancing the Tax-Free Tango by Linda Swartz | Available after Purchase |
Transactions - Form, Substance, and Understanding the Limits | Available after Purchase |