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BANKING TAXATION: INTEREST EXPENSE / RENEGOTIATED DEBT
New Developments and Planning Strategies
A Live Two-Hour Audio Seminar from CCH
Thursday, February 25, 2010 - 1 PM Eastern; Noon Central; 11 AM Mountain; 10 AM Pacific
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
Invite Colleagues, Customers, Prospects and Business Referral Sources to Join You!
Be an Expert on Two of the Major Bank Tax Issues of the Day — and Avoid Audit Adjustments
Join nationally recognized experts, Ron Blasi, author of the U.S. Master Bank Tax Guide, and Stuart Zwerling on Thursday, February 25 for a timely and informative two-hour program as they examine in depth two major bank tax issues. In a clear and practical manner, our distinguished presenters will discuss all relevant aspects relating to the deductibility of interest expense that may be allocable to tax-exempt obligations and the treatment of loans and other debt instruments that banks may negotiate. This seminar follows the very successful CCH bank taxation audio seminar presented in October 2009 that covered in an abbreviated manner these and several other hot bank tax topics. Presentation materials for this February 25th session will be linked to detailed discussions of the related topics found in the U.S. Master Bank Tax Guide.
In the segment of this seminar that addresses interest expense, Blasi and Zwerling will go beyond the recent statutory changes that liberalize the deductibility of interest expense and examine the erosion of the historical limitations on the denial of deductibility of interest expense. They will cover judicial developments relating to consolidated income tax returns and S corporations. Relating to renegotiated debt, Blasi and Zwerling will discuss the planning opportunities for taking a tax deduction when there is not book charge-off. They will discuss the interrelationship between the mark-to-market rules and the amount that can be deducted when a debt is renegotiated. Time will be provided for asking questions directly to Mr. Blasi and Mr. Zwerling via phone or email during the program.
Program Topics
Topics to be addressed by Ron Blasi and Stuart Zwerling include:
INTEREST EXPENSE:
- Characteristics of interest expense
- Deferred interest expense
- Market discount bonds
- The UNICAP rules
- The 2% rule under § 265(a)
- Interest disallowance under § 265(b)
- Interest disallowance under § 291(e)
- The new treatment of QTEOs
- The IRS approach to consolidated disallowance
- The special treatment of S corporation banks
RENEGOTIATED DEBT:
- Determining when there is a deemed exchange
- When there will be a nontaxable alteration
- Application of the “economic significance rule”
- The 5 changes that will trigger a taxable event
- Measuring gain or loss
- Deemed charge-off rules
- Application of mark-to-market rules
Who Should Attend?
- This seminar is essential for all Financial Institution Tax Executives, Directors, and Managers; CFOs, Comptrollers, Treasurers and Tax Counsel of Financial Institutions; CPA Firm Partners, Senior Managers, Managers and Staff with Financial Institution clients; and Auditors who work with banks or S&Ls
Learning Objectives
- Gain practical understanding of the deductibility of interest expense that may be allocable to tax-exempt obligations
- Explain the tax treatment of loans and other debt instruments that banks may negotiate
- Identify planning opportunities to reduce bank tax liabilities
SPECIAL BONUS
Register today for this insightful program on Thursday, February 25 at 1 PM Eastern, Noon Central; 11 AM Mountain; 10 AM Pacific.
About the Speakers:
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RONALD W. BLASI, J.D., LL.M.
Ron Blasi is the Mark and Evelyn Trammell Professor of Tax Law at Georgia State University College of Law. He is the author of the U.S. Master Bank Tax Guide, published by CCH. Ron has served as Chair of the American Bar Association Tax Section's Committee on Banking and Savings Institutions. He has taught in-house courses to bank and accounting firms and he has served as an instructor and consultant to the IRS, FDIC, New York State Legislative Tax Study Commission, and numerous accounting firms and banks. His work experience includes serving as a tax attorney for Citibank and heading up the tax audit and research group at what is now JP Morgan Chase. Ron is currently Professor of Law in the College of Law at Georgia State University. He has a J.D. degree from St. John's University College of Law and an LL.M. (taxation) degree from New York University Graduate School of Law. |
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STUART ZWERLING, CPA, J.D.
Stuart Zwerling is a tax partner in the financial services practice of Deloitte Tax LLP, located in New York. Stuart has more than 24 years of tax experience specializing in tax issues relevant to domestic banks, community banks and international banks. His expertise encompasses assistance and advice with respect to the merger and acquisition activity of both domestic and international banks, performance of cost allocation studies, experience in providing federal, state and local tax advice for domestic and international banks, assistance to banks with respect to tax accounting for financial products and advice regarding the interest expense allocation rules under Reg. Sec. 1.882-5. Stuart also frequently lectures at domestic and international banking seminars. Stuart received his B.B.A. in accounting from Hofstra University, and holds a J.D. from Widener University School of Law, and an LL.M. in taxation from New York University School of Law. Stuart is a CPA in both New York and Maryland and is admitted to the bars of both New York and Connecticut. |
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
Visit CCHGroup.com/AudioSeminars for more audio seminar topics, dates and times!
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Earn CPE Credit
- Two hours of CPE credit. One free CPE certificate for one person is provided with each site registration. CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: Basic knowledge of federal income taxation of banks
- Learn More About CCH’s NASBA Registration
Special Bonus
Firms registering for this audio seminar will receive as a bonus the following publication:
Order CD Recordings of CCH Audio Seminars
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
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Site License: $249 — Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. Each Site License registration includes one free CPE certificate for one person at your site. Additional CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
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CD Recording: $249 — The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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Site License and CD Recording Package: $349 — This specially-priced package provides you with the Site License access to the live audio seminar event AND the CD Recording.
Our Guarantee
If for any reason you are not completely satisfied with this program, we will provide a full refund - no questions asked!
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
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