The International Tax Institute, Inc. holds monthly seminars in mid-town Manhattan on current subjects of international tax law.
We provide New York State continuing legal and professional education (non-transitional CLE and CPE) credits to international tax attorneys and accountants. Founded in 1961, we are a 501(c)(3) organization.
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Dual consolidated loss rules are among the earliest enacted instances of the "linkage approach" now endorsed by the OECD BEPs initiative to prevent hybrid mismatches. Under a linkage approach, the tax treatment of a transaction depends on foreign law, i.e., the consequences of the transaction in a second jurisdiction. Two of the principal drafters of the current U.S. dual consolidated loss rules and a specialist on the OECD BEPs initiative will review the BEPS proposals on dual consolidated losses against the backdrop of the U.S. and U.K. historical experience with their own dual consolidated loss regimes and the interaction between the two. What emerges is a cautionary tale of the difficulties presented by the linkage approach -- daunting complexity, difficulty understanding foreign law, risk of double disallowance of deductions, and complications arising from base and timing differences -- as well as perhaps some lessons learned about design features that can ameliorate some of the harshest aspects of a dual consolidated loss regime.
Time: 8:30 a.m. to 9:00 a.m. Registration and Breakfast
9:00 a.m. to 10:00 a.m. Program
Location: Grand Hyatt New York at 109 East 42nd Street, New York, NY
To register, click "Online Store"
Our Corporate Members:
Alston & Bird LLP
The Bank of Tokyo-Mitsubishi UFJ, Ltd.
Blake, Cassels & Graydon LLP
Boies, Schiller & Flexner LLP
Bryan Cave LLP
Cadwalader, Wickersham & Taft LLP
Capita Asset Services (US)
CBIZ MHM, LLC.
Cleary Gottlieb Steen & Hamilton LLP
Curtis, Mallet-Prevost, Colt & Mosle LLP
Davies Ward Phillips & Vineberg LLP
Dentons US LLP
Ernst & Young
Fox Horan & Camerini LLP
Gide Loyrette Nouel LLP
Greenberg Traurig LLP
Holland & Knight LLP
Kaye Scholer LLP
Kostelanetz & Fink LLP
Loyens & Loeff
Marks Paneth & Shron LLP
Mayer Brown LLP
McDermott, Will & Emery LLP
Osler, Hoskin & Harcourt LLP
PKF O'Connor Davies
Proskauer Rose LLP
Roberts & Holland LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Stroock & Stroock & Lavan LLP
Tozzini, Freire, Teixeira e Silva Advogados
Viacom International, Inc.
Weil, Gotshal & Manges LLP
Winston & Strawn LLP