YIN USA EVENT – SEPTEMBER 17, 2020

YIN Banner EVENTS20 ON BEHALF OF IFA USA


THURSDAY, SEPTEMBER 17, 2020

 

 


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IFA CANADA YIN MEMBERS: MUST USE PROMO CODE YIN

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AGENDA

Thursday, September 17, 2020
11:50 a.m. – 1:30 p.m. (EDT)

 

Loss Limitation Rules in Cross Border Transactions

The presentation will survey the rules that could prevent multinational corporations and investment funds/partnerships from fully recognizing or utilizing losses incurred in cross-border transactions. The presentation will include a discussion of (1) the newly issued Section 163(j) Regulations as applied in the cross-border context, (2) the section 267A anti-hybrid rules, (3) the section 250 loss limitation rule as applied to GILTI and FDII, and (4) the rules governing GILTI tested losses. The interaction of loss carryover rules and the CARES act also will be considered.


Chair
: Mindy Herzfeld, University of Florida, Gainesville, FL and Ivins Phillips & Barker, Washington DC

Speakers:
Witek Jurewicz, DLA Piper, New York, NY
Zackary Pullin, Sidley Austin LLP, Houston, TX
Hans Tanzler, PwC, Washington, DC
Brenda Zent, U.S. Treasury (invited)
Brett York, U.S. Treasury (invited)

Registration:
IFA Canada YIN member can join this webinar for free using the promo code: YIN

 

 
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