Beyond Labels: Exploring the Revised Scope of the Final & Temporary §385 Debt-Equity Recharacterization Regulations

Featuring a Live Q&A with Daniel McCall, Esq. – IRS, Deputy Associate Chief Counsel (International)

Wednesday, November 2, 2016 | 6 pm – 8:30 pm 

Program Co-Chairs:

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

  • 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.

    Live Program & Webcast$149.00 Member | $249.00 Nonmember
    Academic/Government/Non-profit/Students: $74.50 Member | $124.50 Nonmember
    Small Law Firm: $99.00 Member

  • 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)

    Lee Sheppard
    Contributing Editor
    Tax Notes

    Alan J. Tarr
    Loeb & Loeb LLP

  • 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

  • NY: 2.5 professional practice
    NJ: 2.5 general
    CA: 2.5 general
    PA: 2.5 general

  • 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 |