A two-day technical update with group live instruction on the latest tax, legal and financial developments and opportunities affecting the global structured financial products market

Benefits of Attending

• Learn from our faculty of financial, tax and legal professionals the status of the current market and what to expect in the future
• Understand the challenges and opportunities in structuring "Repo" transactions
• Managing operational risk for financial institutions
• How are counterparty risk considerations affecting use of financial products between financial institutions, including sovereign debt developments - Ways to mitigate these risks
• Understand the latest US & European legislative and regulatory developments affecting US and non-US financial institutions -
  Update on FATCA developments
• Update on innovative tier 1 capital products for financial institutions - Tax aspects of debt buy backs, trades, joint ventures and convertibles
• Total return and equity swaps-anti abuse and IRS tax reporting and compliance developments
• Hear from specialists from the following jurisdictions discuss the most up-to-date information regarding financial products and tax developments: *Ireland *UK *Benelux*France*Germany* Eastern & Central Europe *Hot emerging products and markets
• Participate in networking sessions to expand new contacts and renew past relationships and much more…

Educational Course Credit — Up to 12 CPE / CLE Credits Available

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows."

CITE's block of discounted sleeping rooms is limited - reserve your sleeping room early! We cannot guarantee rates or availability. A very limited block of rooms at a reduced rate has been set aside for CITE attendees. For conferences being held at local firm centers, hotel blocks have not been arranged and accommodations are at your own discretion

8:00 Registration and Continental Breakfast

8:40 Welcome and conference overview
Co-chairs:  Mark Leeds, Greenberg Traurig, New York,  Bruno Gouthiere,  CMS Bureau Francis Lefebre, Paris , Carl Church, Deloitte, London

8:45 Review and Update of Latest Key Developments Affecting the Structured Financial Products Market

9:15 Challenges and Opportunities Facing  “Repos” and other Funding  Products-State of the Market

10:00- Country Review - Session 1. -Developments in Ireland Regarding Financial Products and Cross-border Tax Strategies

10:45   Break for Refreshments

11:00- Understanding the Latest US  Legislative & Regulatory Developments affecting Financial Products and Financial Institutions

• Current developments related to the US Government focus on offshore tax evasion
• Legislative tax  development focusing on banking institutions
• Proposed new US qualified intermediary II rules,  FATCA &FFI
• Withholding tax audits
• Cross-border discovery –tools available to the IRS
• JITSIC- latest update on what they are doing
• Developments in  Switzerland in regard to bank secrecy

11:45 – Country Review - Session  2.- United Kingdom- Review of Major  Tax , Political and Financial Developments affecting Financial products and Financial Institutions

12:40 –Summary and Q&A

12:45 – Welcome Luncheon

13:45  - Managing Operational Risk for Financial Institutions

• Dealing with increased audit scrutiny
• Treaty claim process
• Beneficial ownership issues
• Increase in reporting requirements
• Difficulties in claiming treaty claim benefits
• EC developments on withholding taxes
• Work of the OECD & European Commission
• Impact of FATCA

14:45 –Panel Discussion on  Tier 1 Capital Products- Meeting Requirements Utilizing Tax Strategies  and Innovative Structured Financial Products

• Debt-buy backs
• Managing the tax bill to enhance  Tier 1 generation
• Generating Tier 1 capital-use of joint venture partners
• Convertibles- issuing/buying convertible debt
• Case studies

15:45 –Break for Refreshments

16:00 –Country Review 3. Benelux Panel( Belgium, Netherlands and Luxembourg) – Key tax Developments and Strategies related to Financial Products and Financial Institutions

17:15  Total Return and Equity Swaps- Update on Tax Reporting and compliance Developments-Issues involving non-US persons (FFIs)

• Equity swaps-what are they and how have they been used
• Direct holdings of equities by non-US persons versus use of swaps
• Dividend withholding issues
• Equity swaps in regard to anti-abuse issues
• Recent IRS developments in regard to total return swaps
• Update on legislative developments

18:00 – First Day Adjourns – Cocktail Reception begins

Wednesday, November 10, 2010

8:30 Continental Breakfast

8:55 Co-chairs Review of Day One

9:00 AM –Country Review 4. –France- Domestic and Cross-border Products Utilized and Key Tax Cases

• Auditing arbitrage transactions (such as repos, hybrid debt/equity instruments) by French and US tax authorities
• Review of recent practice on exchange of information, access to documents, including lawyers opinions etc.
• Current practice of debt/equity swaps in restructuring operations involving French parties;
• Legislative update on French WHT on payments to non-cooperative states and territories (a possible comparison with FATCA) -  impact on gross-up clauses in negotiable instruments and syndicated loans;
• Update on French case law on abusive transactions

9:45 – Country Review Session  5 –Germany- Update on Tax   and Regulatory Development Issues Affecting Financial Products and Financial Institutions

10:30 –Refreshment Break

10:45 –Country Review- Session  6—Eastern & Central European Panel – Including Austria, Czech Republic, Hungary,  Poland and possibly Slovakia - Tax and Financial Products developments in regard to Banks and Capital Markets

12:00- Hot Emerging Issues,  New Markets & Products & Developments Facing Global Financial Institutions Resulting from the Banking and Financial Crisis

• Bank levies
• Financial activities Tax
• OECD initiatives affecting banks and financial institution
• Basle III developments affecting bank capital requirements
• Dealing with counterparty risk  in relation to the Sovereign debt crisis
• Emerging markets for structured financial products

12:45 Summary and Q&A

13:00 – Going Home Luncheon

14:30 – Summit Ends

CITE Conference Registration - Page 1

There are 3 ways to register for a CITE Conference:

1. Complete this form and fax Page 2 to 914-328-5757
2. Call us directly at 914-328-5656
3. Complete the online registration process

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