Beyond Labels: Understanding the Deeper Practice and Policy Implications of Proposed §385’s Debt-Equity Recharacterization Rules

Program Co-Chairs:

John C. Dworkin, John C. Dworkin P.C.
Emmanuelle M. Henry, Ernst & Young, LLP

• Description
• Faculty
• Agenda
• CLE Credit
• Sponsors

• On April 4, 2016, the IRS issued proposed regulations under Code §385 that far exceeded the scope of the revised inversion rules that the business and tax community had anticipated. Following significant public and Congressional scrutiny and debate, on October 13, 2016, Treasury released more narrowly tailored Final & Temporary regulations that contain a number of exceptions that were presumably designed to respond to the numerous public comments that were filed with the IRS. The Taxation of Business Entities Committee of the New York City Bar Association invites you to join us, renown tax policy speakers Lee Sheppard & Prof. Daniel Shaviro, practice area specialists, and industry representatives for a CLE event that will explore the basic structure of the Final & Temporary regulations, the ways in which the Final & Temporary regulations differ from the broader regulations that were initially proposed, the practical implications of the new rules from an industry perspective, and some of the relevant administrative law and tax policy implications.

  DVDs & CDs: $149 Member | $249Nonmember
  On-Demand: $119 Member| $219 Nonmember
  Materials Only (No CLE Credit): $99 Member | $129 Nonmember

  * New York residents will be charged the New York sales tax for all audio visual purchases.

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• Rebecca Attwell
  Ernst & Young LLP

  John P. Barrie
  Bryan Cave LLP

  Allen Friedman
  Vice President of Tax
  JP Morgan

  Daniel McCall
  Deputy Associate Chief Counsel (International)
  IRS

  Lee Sheppard
  Contributing Editor
  Tax Notes

  Alan J. Tarr
  Loeb & Loeb LLP

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• 6 – 6:10 pm	Introductions Emmanuelle M. Henry
  6:10 – 7:10 pm	Introduction to Proposed Sec. 385 Regulations & Practice Area Insights                                                           Alan Tarr, Rebecca Atwell, Dan McCall
  7:10 – 7:25 pm	Break
  7:25 – 7:55 pm	Introduction to Proposed Sec. 385 Regulations & Practice Area Insights                                                         John Dworkin, Allen Friedman, John Barrie, Dan McCall
  7:55 – 8:20 pm	Policy Implications and Administrative Law Considerations                                                             Lee Sheppard, Dan McCall
  8:20 – 8:30 pm	Q&A

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• This program provides 2.5 credits in professional practice for the New York & New Jersey MCLE requirements. California & Pennsylvania credit differs as it is based on a 60-minute credit hour. The live program provided transitional credit to newly admitted attorneys; the recording does not provide transitional credit.
  

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• Sponsoring Association Committee:
  Taxation of Business Entities Committee | Philip (Phil) S. Gross, Committee Chair

  Sponsorship Opportunities are Available! Please Contact:
  Maricela Alfonso| Membership and CLE Relations Associate| (212) 382-6608 | MAlfonso@nycbar.org
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