Overview
On November 17-18, Brian H. Jenn and Jenny L. Johnson will be speaking respectively at Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2022 by Practicing Law Institute held in Chicago.
Agenda:
November 17 | 4:15 PM CST
Restructuring Multinational Groups | Brian H. Jenn
Cross-border structuring issues and the impact of GILTI, foreign-derived intangible income (“FDII”), base erosion anti-abuse tax (“BEAT”), Section 163(j) and anti-hybrid rules, as well as pending legislative and international proposals, the location of third-party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements
November 18 | 1:15 PM CST
Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know | Jenny L. Johnson
Ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct