Feb

    Debt/Equity Rules: Applying the Final Section 385 Regulations

    1 PM GMT

    In October 2016, the Treasury Department and IRS released final and temporary regulations under Section 385 addressing the treatment of related party debt for U.S. tax purposes, including detailed documentation requirements and controversial recast rules. While the sweeping scope of the proposed rules has been narrowed in the final package, the Section 385 regulations represent a significant change from prior practice and present a number of practical challenges. In this webinar, IRS representatives and leading practitioners will discuss the documentation requirements as they are in effect today, as well as offer insights regarding the application of the documentation and recast rules in specific contexts, including cross border financing transactions, investment management structures and affiliated groups.

    Featured Speakers

    Gregory N. Kidder, Steptoe & Johnson LLP, Washington, DC (Moderator)

    Kevin M. Jacobs, IRS, Washington, DC

    Eileen Marshall, Wilson Sonsini Goodrich & Rosati, Washington, DC

    Joshua G. Rabon, IRS, Washington, DC

    Wade Sutton, PwC, Washington, DC

    PLEASE NOTE: To receive CLE credit, each individual attendee must be logged into the webinar interface for the ENTIRE program (including the Q&A). Partial credit is not available for this program. Please see the CLE Informaton page for more details.

    Registration Fees
    FEES*
    $75 for Section of Taxation Members
    $150 ABA Member*
    $125 Young Lawyers
    $125 Government / Academic / Non-Profit
    $195 All other registrants
    FREE Full-time J.D., LL.M., or M.T. Candidates (No CLE Credit/Webcast Only)
    FREE Press
    *ABA Member registrants will become Tax Section members for 2016-17.
    Fee includes an mp3 audio recording that is available within one week following the program date.
    Discounts Available for Group Registrations: Please e-mail Thomas Blandi (thomas.blandi@americanbar.org) for more information.
    Law Student registrants, who are current nonmembers, will also receive complimentary membership to the ABA and the Section of Taxation.

    $195
    NON-MEMBERS
    $150
    MEMBERS
    $75
    SECTION MEMBERS
    Register Now *Additional discounts may apply at checkout

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    Debt/Equity Rules: Applying the Final Section 385 Regulations

    Event Details

    Format

    Web

    Date

    Feb 01, 2017

    2017-02-01T13:00:00 2017-02-01T14:35:00 Debt/Equity Rules: Applying the Final Section 385 Regulations

    In October 2016, the Treasury Department and IRS released final and temporary regulations under Section 385 addressing the treatment of related party debt for U.S. tax purposes, including detailed documentation requirements and controversial recast rules. While the sweeping scope of the proposed rules has been narrowed in the final package, the Section 385 regulations represent a significant change from prior practice and present a number of practical challenges. In this webinar, IRS representatives and leading practitioners will discuss the documentation requirements as they are in effect today, as well as offer insights regarding the application of the documentation and recast rules in specific contexts, including cross border financing transactions, investment management structures and affiliated groups.

    Featured Speakers

    Gregory N. Kidder, Steptoe & Johnson LLP, Washington, DC (Moderator)

    Kevin M. Jacobs, IRS, Washington, DC

    Eileen Marshall, Wilson Sonsini Goodrich & Rosati, Washington, DC

    Joshua G. Rabon, IRS, Washington, DC

    Wade Sutton, PwC, Washington, DC

    PLEASE NOTE: To receive CLE credit, each individual attendee must be logged into the webinar interface for the ENTIRE program (including the Q&A). Partial credit is not available for this program. Please see the CLE Informaton page for more details.

    Registration Fees
    FEES*
    $75 for Section of Taxation Members
    $150 ABA Member*
    $125 Young Lawyers
    $125 Government / Academic / Non-Profit
    $195 All other registrants
    FREE Full-time J.D., LL.M., or M.T. Candidates (No CLE Credit/Webcast Only)
    FREE Press
    *ABA Member registrants will become Tax Section members for 2016-17.
    Fee includes an mp3 audio recording that is available within one week following the program date.
    Discounts Available for Group Registrations: Please e-mail Thomas Blandi (thomas.blandi@americanbar.org) for more information.
    Law Student registrants, who are current nonmembers, will also receive complimentary membership to the ABA and the Section of Taxation.

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