Shearman And Sterling

Event Jan 17, 2017

PLI’s Taxation of Financial Products and Transactions 2017 Seminar

  • New York

Partner Michael Shulman (Washington, DC-Tax) spoke at PLI’s “Taxation of Financial Products and Transactions 2017” seminar on January 17, 2017 in New York. The program gave an overview of the landscape of the taxation of financial products and transactions, and provided new insight to familiar planning strategies. Attendees learned about the latest changes to the financial products area, as a result of activity in both the executive and legislative branches, including:

  • Analyzing the impact of the Section 385 proposed regulations on financial products
  • Exploring the latest withholding tax issues, including contingent interest and commitment fees
  • Examining interesting issues with swaps under current law: 
    • Multiple underlying assets
    • Wash sale/deemed exchange issues
    • Credit default swaps over a foreign currency denominated FX bond
  • Hearing experts’ thoughts on when a derivative over an illiquid asset will be treated as an ownership interest
  • Understanding the implications of Senator Wyden’s legislative proposal to mark-to-market all derivatives
  • Studying the tax issues arising from guarantees in a variety of contexts