A two-day introductory level course with live group instruction on the basic economic and U.S. tax aspects of typical financial products and derivative instruments used in financial markets today.

Benefits of Attending

• Understand the basic instruments used in developing financial products and how the U.S. taxes these instruments
• Learn the latest tax and accounting rules affecting the use of hedges
• Find out the key issues involving COD, OID and imputed interest in determining the taxation of debt instruments
• Update your knowledge of the U.S. tax aspects of current financial products, including repos, distressed debt and convertible instruments
• Discover the U.S. tax rules for foreign currency swap and option transactions under Sec. 988
• Learn the latest techniques for minimizing the results of an IRS audit of financial products or derivatives at your company
• Ascertain how the codification of the economic substance rules will affect your company’s IRS reporting and disclosure requirements

Educational Course Credit — Up to 15 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"

Day One

7:30 am Registration and Continental Breakfast

8:45 am CITE Welcome and Introduction

9:00 am Overview - Fundamental Building Blocks

• Description of the basic instruments used in developing financial products: forwards, options and notional principal contracts
• What are the economics of these instruments?
• Understanding how the U.S. taxes these instruments
• Special rules for business hedges
• Mark-to-market taxation

11:00 am Break for Refreshments

11:15 am Taxation of Debt Instruments

• OID and imputed interest
• Convertible debt and investment units
• Role of public trading in determining debt issue price

12:15 pm Luncheon

1:15 pm Tax Traps

• Section 1256 Contracts
• Wash Sales
• Straddles
• Securities Traders
• Conversion Transactions           

2:30 pm Hot Financial Products

• Recent legislation involving COD income and AHYDO
• Convertible debt with hedge and warrants
• Mandatory convertibles

3:15 pm Break for Refreshments

3:30 pm Accounting for Derivatives and Hedging

• Understanding the principles of FAS 133 for derivatives and hedging instruments
• Comparison of FAS 133 to tax rules related to hedging and derivatives
• Common M-1 adjustments related to hedging and derivative activities
• Understanding the new rules under FAS #161 for disclosure of derivative and hedging activities

5:00 pm Conference Adjourns for the Day

Day Two

8:00 am Continental Breakfast

9:00 am U.S. Taxation of Foreign Currency Gains (Losses)

• Understanding the basic tax rules for QBUs (Qualified Business Units)
• Determining the functional currency, and treatment of Sec. 988 foreign currency transactions
• Tax treatment of foreign currency hedges, options and swaps  

10:15 am Refreshment Break

10:30 am International Financing and Financial Transactions of Foreign Persons

• Application of the U.S. withholding tax provisions
• Generating foreign tax credit benefits
• Latest Subpart F developments involving the banking exception
• Avoiding PFIC status

12:15 pm Luncheon

1:15 pm Tax Controversies Involving Financial Products

• How recent tax cases change the landscape for the IRS, taxpayers and the market
• How taxpayers can best support and defend their financial transactions
• Preserving privilege on financial products transactions while living in the glass house of FIN 48
• Responding to requests for electronic documents  

2:30 pm Refreshment Break 

2:45 pm Disparate Tax Treatment of Economically Equivalent Investment Tool

• Various investment “tools” achieve economically equivalent results
• Tax treatment of these tools is disparate
• Opportunity - select the tool that should deliver the optimal tax result
• Real world applications: single stock concentration risk management, portfolio hedging, structured products

4:00 pm         Conference Ends

Bloomberg BNA | CITE Conference Registration - Page 1

There are 3 ways to register for a Bloomberg BNA | 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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