ARLINGTON, Va., Oct. 7 /PRNewswire-USNewswire/ -- At a time when lending institutions are naturally risk-averse, multinational corporations increasingly find themselves providing guarantees to enable group members to obtain loans on satisfactory terms. Where a cross-border element is involved, analyzing the potential tax consequences can be complex and subject to a degree of uncertainty. The tax treatment of loan guarantee fees has been receiving a lot of attention lately, particularly in light of the GE Capital case in Canada, the Container Corp. case in the U.S. and the September 27 law effectively overturning the decision in the latter case.
On October 22, a new webinar from BNA, Tax Treatment of Loan Guarantees: A Multijurisdictional Perspective, immediately following the Tax Management International Forum meeting in London, will draw on leading experts from the U.K., U.S., Netherlands, and Belgium who will examine their own and other countries' perspectives on the tax treatment of loans.
In this premiere 60-90 minute webinar event, registrants will get the details on the tax treatment of loan guarantees in the U.S. and Europe as expert panelists address:
- Deductibility of loan guarantee expenses
- Taxation of loan guarantee income (both under domestic law and within a treaty context)
- Viability of obtaining deductibility of a guarantee expense and non-taxation of the guarantee income
- Determining arm's-length pricing for loan guarantees
- Special considerations where a loan guarantee is provided by a head office to a foreign branch or permanent establishment
There has never been a more critical time for multinationals and their tax advisers to familiarize themselves with the issues surrounding the U.S. and European approaches to the taxation of loan guarantees.
NOTE: All registrants will additionally receive a copy of the September 2010 issue of the Tax Management International Forum, containing papers by practitioners in 15 different countries discussing the tax treatment of loan guarantees in their particular country.
Moderator & Speakers include:
Jones Day, Belgium
McDermott, Will & Emery UK LLP
Carola van den Bruinhorst
Loyens & Loeff, The Netherlands
Loyens & Loeff, The Netherlands
Buchanan Ingersoll & Rooney PC, USA
Tax Treatment of Loan Guarantees: A Multijurisdictional Perspective takes place October 22, 2010, from 10:30 am – 12:00 pm, ET). To register for this webinar and obtain further information about CLE and CPE credits, go to http://www.mmsend10.com/link.cfm?r=597826919&sid=10918161&m=1126721&u=BNA_TAXP&s=http://www.bnatax.com/loan-guarantees-webinar/?open&cmpid=tmtxac2010 or (in the U.S.) call 1-800-372-1033, menu Option 6, then Option 1. The per site fee is $249.
To receive automatic, email notification of upcoming BNA webinars that may be of interest to you, go to: http://www.bna.com/emailsignup.htm
About BNA Tax & Accounting Webinars
BNA Tax & Accounting is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants. Designed for today's busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all BNA Tax & Accounting resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area — and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits — all from the convenience of their own office or conference room.
About the Tax Management International Forum
Leading tax practitioners from 15 different countries gather twice-yearly in London and Paris to provide a comparative discussion on single, key international tax topics. Each Forum member explains how they would deal with the tax issue in question, and their solutions, comments and analysis offer subscribers a detailed view of tax insights in different countries — thus providing an efficient, practical way to obtain country-specific tax insights.
SOURCE BNA Tax & Accounting