New Rules for Distressed Debt: Boon or Bane?
Overview:
The continuing economic turmoil may offer rare opportunities for investors and companies to acquire distressed debt at deep discounts. However, there are complex tax rules and information reporting requirements which govern the acquisition of distressed debts.
Tax professionals, finance executives and investors must have a comprehensive understanding of the issues when acquiring distressed debt such as tax, legal, audit and valuation. This live webcast will help you maximize your returns while minimizing risk.
The Knowledge Group is assembling a panel of speaker experts who will share their opinions in a two-hour webcast. A live interaction with the audience in a question and answer format is also included in this event.
Advanced registration is recommended as space is limited. Register early and save! Click the “Register” button below to sign up for this course today.
Agenda:
- I. Introduction
- Economic Environment – 2008 to Present
- Tax Guidance
- II. Basic Tax Principles
- Events Resulting in Taxable Exchange and COD Income
- Situations Resulting in OID
- Rules for Significant Modification
- Enactment of Section 108(i) Applicable AHYDO Rules
- III. Publicly Traded Debt – Recently Issued Proposed Regulations
- Existing Rules
- Areas of Debate
- Application and Relevance of Proposed Rules
- Compliance Issues
- IV. Issuer’s Credit Deterioration
- Uncertainty Regarding Prior Version of Treas. Reg. Sec. 1.1001-3(e)(5)(i)
- New Regulation
- V. Payments on Distressed Debt
- Inclusion of Interest and OID
- Issuer’s Interest Deductions
- Allocation of Payments
- VI. Market Discount Rules
- VII. Distressed Debt Acquisitions Resulting in Engaging in a U.S. Trade/Business (ETB)
- When Is a Foreigner Treated as ETB?
- Safe Harbor
- Situations Raising ETB Issues
Who Should Attend:
- Attorneys and Consultants
- Legal Advisors
- Distressed Securities/Hedge Funds Professionals
- Portfolio Managers
- Financial Executives and other related Professionals
- Accountants
- CEOs, Presidents, CFOs and other Senior Executives
- Fixed Income Directors and Managers
- Tax Professionals
Richard Nugent is a transactional lawyer with significant expertise in the tax aspects of public and private corporate mergers, acquisitions, …
Victor Hollender advises on a wide range of U.S. and international tax matters, including mergers and acquisitions, divestitures, cross-border financings, …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
NONE
Course Code:
104076
Total Credits:
2.0 CLE
Login Instructions:
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SPEAKERS' FIRMS:
About Deloitte Tax LLP
Website: https://www.deloitte.com/
About Cadwalader, Wickersham & Taft LLP
Website: https://cwt.com/
About Skadden, Arps, Slate, Meagher & Flom LLP
Website: https://skadden.com/