Financial Institutions & Products

$45.00

Chair: Craig Gibian, Deloitte Tax LLP, Washington, DC

Section 871(m) Update.
This panel will discuss practical issues under section 871(m) and areas in which revisions to the section 871(m) regulations or further guidance might be warranted. The topics that will be discussed include the combination rule, qualified derivatives dealers, non-delta-one derivatives, qualified indices, and derivatives over partnerships.
Moderator: Jeffrey Hochberg, Sullivan & Cromwell LLP, New York, NY
Panelist: Jay Klein, PwC, New York, NY; Erika Nijenhuis, Senior Counsel, Department of Treasury, Washington, DC (Invited)

Transitioning from LIBOR.
This panel will discuss the proposed regulations released in October 2019 regarding the tax implications of transitioning away from LIBOR. Topics will include the application of section 1001 and the VRDI rules.
Moderator: Lucy Farr, Davis Polk & Wardwell, New York, NY
Panelist: Diana Imholtz, IRS, Office of Associate Chief Counsel (FI&P), Washington, DC (Invited); Jeff Maddrey, PwC, Washington, DC; Brett York, Acting Deputy Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited)

Section 163(j): Peaking (or is that PIKing) your Interest.
If final regulations are issued in time (or proposed regulations are reopened), this panel will discuss the definition of interest and other rules under section 163(j) that are particularly relevant to the financial transactions community. To the extent there is a deferral in the issuance of regulations, this panel will convert into a discussion of issues that currently arise under section 163(j), including under the proposed regulations, and other debt-related topics.
Moderator: Michael Yaghmour, EY, Washington, DC
Panelists: Diana Imholtz, IRS, Office of Associate Chief Counsel (FI&P), Washington, DC (Invited); Brett York, Acting Deputy Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Michael Mou, Deloitte Tax LLP, Washington, DC

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