Taxation of Financial Products & Transactions 2022 | Practising Law Institute (PLI) | 10 January 2022 | Practising Law Institute & Online, 1177 6th Ave, New York, NY 10036, USA

Why You Should Attend?
The popularity of cryptocurrency is forcing taxpayers to apply old principles to new issues, while multinational corporations must deal with new constraints on their ability to design tax-efficient structures. Additionally, financial institutions continue to face new tax issues, the IRS prepares systematic challenges to taxpayers that cross the line and become “a U.S. trade or business,” and special purpose acquisitions companies (“SPACs”) raise interesting issues for discussion. This year’s program will help attendees understand the impact of these new developments on the taxation of financial products and transactions, while also exploring familiar topics including the age-old debt equity distinction.

What You Will Learn?
• Complex issues arising from holding stock and warrants in SPACs
• What to expect from the IRS’s new compliance initiative focused on inbound lending
• Cutting-edge topics involving cryptocurrency
• Approaching debt-equity issues from the lender’s perspective
• Sophisticated tax planning for multinational corporations in the post-BEPS world
• Current issues in the taxation of banks (and their clients)

Who Should Attend?
Attorneys at law and accounting firms who advise clients on financial transactions and products; in-house tax professionals who help structure transactions and make ASC 740 determinations; hedge fund traders and portfolio managers who want a better understanding of the tax rules governing financial products and transactions; accountants who work in the area of financial products; people who advise hedge fund managers, banks, and insurance companies; and government attorneys who want to stay on top of what’s happening in the capital markets will all benefit from attending this program.

2022 Speakers

CHAIRPERSON:

Matthew A. Stevens
Principal, EY

SPEAKERS:

Pamela Lawrence Endreny
Partner, Gibson, Dunn & Crutcher LLP

Lucy W. Farr
Partner, Davis Polk & Wardwell LLP

Sandra Gurijala
Partner/Principal, EY

L.G. "Chip" Harter
Senior Policy Advisor, PwC

John E. Hinding
Director, Cross Border Activities Practice Area; Large Business and International (LB&I), Internal Revenue Service

Jeffrey D. Hochberg
Partner, Sullivan & Cromwell LLP

Cindy S. Kim
Program Manager, Cross Border Activities Practice Area; Large Business and International (LB&I), Internal Revenue Service

Mary Jo Lang
Senior Manager, Deloitte Tax LLP

Stuart E. Leblang
Co-Head, Akin Gump Strauss Hauer & Feld LLP

Nicholas A. Machen
Director and Tax Counsel, Citi

Sanjeev Magoon
Principal, PwC

David S. Miller
Partner, Proskauer

Erika W. Nijenhuis
Senior Counsel, Office of Tax Policy, U.S. Department of the Treasury

Vadim Novik
Executive Director, JP Morgan Chase & Co.

Paul W. Oosterhuis
Of Counsel, Skadden, Arps, Slate, Meagher & Flom LLP

David T. Plastino
Principal, The Brattle Group

Peter Psiachos
Senior Tax Counsel, Coinbase

Danielle E. Rolfes
Co-Partner-in-Charge, Washington National Tax- International Tax, KPMG LLP

Elena V. Romanova
Partner, Latham & Watkins LLP

Jason D. Schwartz
Tax Partner, Cadwalader, Wickersham & Taft LLP

Michael B. Shulman
Co-Head of the Tax Group, Shearman & Sterling LLP

Diana L. Wollman
Partner, Cleary Gottlieb Steen & Hamilton LLP

Jason Yen
Associate International Tax Counsel; Office of Tax Policy, U.S. Department of the Treasury

Lisa M. Zarlenga
Tax Partner, Steptoe & Johnson LLP