Matthew Stevens and Clay Littlefield participated in this multi-city webcast program hosted by
Practising Law Institute (PLI). Matthew Stevens was the program chair and was a featured panelist during the session, "Section 871(m): What Is, and What Will Never Be?" Michael's session covered the following topics.
- Audit update
- Discussion of the new regulations (if issued)
- Beyond the regulations
Clay Littlefield was a featured panelist during the session, "Regulated Investment Company (RIC) Update." Clay's session covered the following topics.
- RIC investment in commodities
- Implementation of the RIC Modernization Act of 2010
- Other recent developments
With implementation of the Dodd-Frank Act underway, and judicial and administrative scrutiny remaining at a high level, it is important to stay on top of the latest developments in the fast changing area of financial products and transactions. This program explored new topics in financial transactions and examine new angles on some of the familiar ones. The following topics were discussed.
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How the IRS’s Large Business and International Division (LB&I) has stepped up to provide its own brand of informal tax guidance
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Key tax issues clients will face under Dodd-Frank (including but not limited to issues arising under section 1256)
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The latest theories on which strategies to reduce dividend withholding taxes will survive the enactment of section 871(m)
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Can the contingent capital transactions used in Europe produce Tier One capital with deductible payments in the United States?
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The latest happenings in the increasingly important world of regulated investment companies (RICs)
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Techniques for dealing with different financial transactions that have the same economic results but produce different tax consequences
Alston & Bird is a privileged member of PLI and colleagues of the firm can view the webcast or attend the live program at no cost. Contact Robin Goldstein at
for further details.
January 17, 2012
PLI New York Center / New York, NY