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Tax Planning for Joint Ventures
Tax Planning for Joint Ventures
Recorded on Sept. 2015. No CE credits are offered for self study products
Foreign joint ventures have become increasing popular due to a variety of reasons for U.S. based companies. Whether acquiring an established controlled foreign corporation or starting a new entity, legal and tax uncertainties will arise. This webinar will provide an understanding of the newly issued proposed and temporary regulations under Section 956 and transfers of property to partnerships. Chris Bowers and Robert Stevenson from Skadden, Arps, Meagher, & Flom will discuss:
- Notice 2015-54 – Regulations to be Issued Regarding Transfers of Property to Partnerships with Related Foreign Partners
- Section 721(c) Partnerships
- The Gain Deferral Method
- Acceleration Events
- Newly Issued Proposed and Temporary Regulations under Section 956 Regarding United States Property Held by Controlled Foreign Corporations
- Partnerships Formed or Funded with a Principal Purpose of Avoiding Section 956
- Leveraged Distributions by Partnerships
- United State Property held by Partnerships
- Treatment of Partnership Obligations
Prerequisite: Knowledge of Cross-Border Transactions
Delivery Method: Group Internet-Based Live
Recommended CPE Credit(s): 1.5 Credit
Field of Study: Taxes
Who Should Attend: Corporate tax and finance executives, accountants, CPAs, tax attorneys and corporate counsel.
About our Speakers
Chris Bowers is a partner at Skadden, Arps, Slate, Meagher & Flom LLP. He advises clients on all aspects of international tax planning and controversy, representing many of the largest U.S. and international financial institutions, as well as large, multinational companies. He focuses on issues arising in cross-border financings, cross-border mergers and acquisitions, and foreign tax credit planning. Before joining Skadden in 2014, he was a partner at another global law firm. Prior to that, he was a partner in the International Corporate Services Group at KPMG LLP’s Washington National Tax Office. Earlier in his career, Mr. Bowers clerked for Supreme Court Chief Justice William H. Rehnquist and the Hon. Pamela Ann Rymer of the U.S. Court of Appeals for the Ninth Circuit. Mr. Bowers is listed as one of the country’s leading tax practitioners in Chambers USA: America’s Leading Lawyers for Business. He also has been included in The Best Lawyers in America, The Legal 500 U.S. and International Who’s Who of Corporate Tax Lawyers. Mr. Bowers has co-authored numerous articles on a wide range of international topics that have been published in leading tax journals, including Tax Management International Journal, Tax Notes and Tax Notes International. He also is an adjunct professor at Georgetown University Law Center, where he teaches international taxation, and served as an adjunct professor of law for corporate taxation at the George Mason University School of Law in 2004.
Robert C. Stevenson is an associate in the tax group at Skadden, Arps, Slate, Meagher & Flom LLP and represents clients on a broad range of tax matters, with a particular emphasis on international tax matters, including cross-border acquisitions and joint ventures, post-acquisition integration and restructuring transactions, public and private company mergers and acquisitions, spin-offs and subpart F and foreign tax credit planning. Mr. Stevenson also advises clients in the financial services sector on insurance-related corporate transactions, including reinsurance transactions, restructurings and related matters. Mr. Stevenson received his J.D. and LL.M. from the Georgetown University Law Center in 2010 and 2011, respectively, and is admitted to practice in New York, New Jersey, and the District of Columbia.