Financial Products and Transactions

An overview of innovative tax strategies involving complex derivatives and other financial instruments including the effects of Dodd-Frank. Topics may include domestic and cross-border tax issues relating to swaps, credit default swaps, caps, floors, collars, options, structured notes and other “prepaid forwards,” exotic convertible debt securities, “hybrid” securities, and various combinations of the foregoing. The panel will discuss the origins of some of the more prominent products in today’s markets (including both the business and tax rationales underlying the products), as well as any recent initiatives by Congress and the Treasury Department to address the various policy issues that they raise.