Alliance for Tax, Legal, and Accounting Seminars
&
Structured Finance Institute

Monday, June 23

8:00am Registration and Continental Breakfast

8:50am Welcome and Conference Overview       

9:00am Section 985 – Functional Currency Determinations
           
10:00am Section 986 – Translation Issues

11:00am Break and Refreshments

11:15am Impact of Section 986 Translation Rules with Respect to Distributions of PTI under Section 959

12:15pm Luncheon

1:15pm Section 987 –Explanation of the New Proposed Section 987 Regulations

3:15pm Break and Refreshments

3:30pm  Section 988 Transactions

4:30pm Questions and Answers.

5:00pm Meeting Adjourned

Tuesday, June 24

8:00am Continental Breakfast

8:50am Welcome and Day 2 Overview

9:00am Overview of Taxation of Hedging FX Risks

11:00am Break and Refreshments

11:15am Subpart F Aspects of Hedging FX Risks

12:30pm Questions and Answers

12:45pm Seminar Adjourns