New York, NY
Fulfill all of your remaining CPE/CLE
credits with entry to an unlimited number of upcoming Bloomberg BNA tax
seminars and webinars in 2016 for less than the price of two seminars.
Click here to learn more and purchase your pass!
A two-day, introductory-level course with live group instruction on the basic economic and U.S. tax aspects of typical financial products and derivative instruments used in financial markets today.
Benefits of Attending:
• Understand the basic instruments used in developing financial products and how the U.S. taxes these instruments
• Learn the latest tax and accounting rules affecting the use of hedges
• Find out the key issues involving COD, OID and imputed interest in determining the taxation of debt instruments
• And more!
All paid attendees will receive the Bloomberg BNA Portfolio (a $400 value):
Financial Instruments: Special Rules #186
*One Portfolio per paid attendee. Quantities are limited.
8:00 am Registration and Continental Breakfast
8:30 am Overview - Fundamental Building Blocks
• Disparate tax treatment of economically equivalent investment tools
• Classification of the basic instruments used in developing financial products: forwards, options and notional principal contracts (swaps)
• Understanding how the U.S. taxes financial product transactions
• Special rules for hedging transactions - identification of hedging transactions – timing and character
10:30 am Refreshment Break
10:45 am Taxation of Debt Instruments
• Understanding original issue discount (OID) and imputed interest
• Role of public trading in determining “issue price”
• Tax consequences of debt modifications
• Distressed Debt Issues for Borrowers and Lenders
12:00 pm Luncheon
12:30pm New Section 385 Regulations
• Identifying expanded group instruments
• Understanding loan documentation requirements
• Per se equity under the general, funding, and anti-avoidance rules
• Treatment of consolidated groups
1:30 pm Anti-Abuse Provisions Affecting Financial Products
• Wash Sales
• Constructive Sales
• Constructive Ownership
• Conversion Transactions
2:45 pm Refreshment Break
3:00 pm Taxation of Repurchase Agreements and Stock Lending Transactions
• Use of stock lending and “repo” transactions
• Basic taxation and scope of section 1058
• Cross-Border Issues
• UBTI Issues
• Short Sales
4:00 pm Hot Financial Products
• Treatment of contingent payment debt instruments
• Contingent Payment Convertibles
• Call Spread Convertibles
• Mandatory Convertibles
5:15 pm Seminar Adjourns for the Day
8:30 am Continental Breakfast
9:00 am U.S. Taxation of Foreign Currency Gains (Losses)
• Understanding the basic tax rules for QBUs (Qualified Business Units)
• Determining the functional currency, and treatment of Sec. 988 foreign currency transactions
• Section 988 foreign currency hedging (integration)
• Subpart F consequences of Section 988 transactions
10:30 am Refreshment Break
10:45 am Accounting for Derivatives and Hedging Transactions
• Accounting for hedges and derivative products – overview of ASC 815(FAS 133)
• Comparison of ASC 815 to tax rules related to derivatives and hedging transactions
• Common book/tax differences and similarities related to hedging and derivative activities
12:15 pm Luncheon
12:45 pm Issues in Resolving Tax Controversies Involving Financial Products
• When is a transaction required to be disclosed – Listed Transactions, Transactions of Interest and other Reportable Transactions
• How recent tax cases change the landscape for the IRS, taxpayers and the market
• How taxpayers can best support and defend their financial transactions
• Preserving privilege on financial products transactions while living in the glass house of FIN 48
• Responding to requests for electronic documents – exchange of information agreements with foreign tax authorities
1:45 pm Refreshment Break
2:00 pm New IRS Disclosure and Anti-Avoidance Provisions Targeting Financial Transactions
• Understanding how the codification of economic substance affects financial products transactions
• Application of the latest Chapter 4 withholding requirements under Secs. 1471 and 1472 – effective date
• Key Issues in completing IRS Form W-8IMY
• Interrelationship with the Chapter 3 withholding tax regime – withholding on interest and gains from sales of financial products
3:30 pm Seminar Concludes
November 14 & 15, 2016
AMA Conference Center
1601 Broadway (at 48th and Broadway)
New York, NY 10019
Hotel accommodations are at your own discretion. We suggest the following:
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000
Novotel of New York
226 West 52nd Street
New York, NY 10019
If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact email@example.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event.
Cancellations must be made in writing to firstname.lastname@example.org more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at 800.372.1033, or e-mail email@example.com.
Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at firstname.lastname@example.org.
Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.
Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.
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