Common Encounters with Sub C, §367 and Other Rules in Restructurings
Tuesday, February 12, 2013 at 8:30 AM (PST)
Registration:................... 8:00 AM – 8:30 AM
Program:......................... 8:30 AM - 12:00 PM
Lunch:............................. 12:00 PM - 1:00 PM
Program:......................... 1:00 PM - 2:00 PM
We are pleased to announce that Latham & Watkins LLP will present a ¾ day seminar on the common tax issues that arise during restructurings and transactions with multinational groups.
The first session, Day to Day Dealings with Subchapter C in Reorganizations and Restructurings, is intended to be a refresher on structuring tax-free transactions in a domestic corporate context. These aren’t the once in a career transactions, but rather common issues encountered when trying to move the boxes around on the structure chart. A list of key topics includes Sections 368, 351, 355, 304, basis recovery and economic substance.
The second session, Common Encounters with Section 367 and Other International Tax Issues, will focus on how Section 367 affects outbound transfers of assets and stock and when such transfers can qualify for tax-free treatment. Also covered will be a number of international restructuring issues common to a US based multinational group.
The third session, Cash Rich Spin-Offs, Morris Trust Transactions and Other Recent Spin-Off Developments and Corporate Inversions/Expatriations, covers topics that have recently received extensive coverage in the business and financial press. When these articles run, CEOs and CFOs, call the tax people and want to know the “why and how”!
Speakers from Latham & Watkins LLP
Grace Chen, Partner (San Francisco)
Nicholas J. DeNovio, Partner (Washington, D.C.)
Larry Stein, Partner (Los Angeles)
Kirt Switzer, Partner (San Francisco / Silicon Valley)
Sam Weiner, Partner (Los Angeles)
When & Where
Tax Executives Institute - Santa Clara Valley Chapter
Tax Executives Institute, Inc. is the preeminent association of in-house tax professionals worldwide. Our members are business executives who are responsible for taxation matters on an administrative or policy-making level, or whose work is otherwise primarily concerned with the challenges of business taxation. TEI members are accountants, lawyers, and other corporate and business employees who are responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity.
The Santa Clara Valley Chapter is the largest TEI Chapter in the world, and reprensents members in and around Silicon Valley in the San Francisco Bay Area.sponsible for taxation matters on an administrative or policy-making level, or whose work is otherwise primarily concerned with the challenges of business taxation. TEI members are accountants, lawyers, and other corporate and business employees who are responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity.