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Insight Center: Webinars

Cross-Border Financing and Currency Hedging After Tax Reform

Speakers: Steven D. Bortnick and John Frey

8/21/2018
1:00-2:00 PM (ET)
Cross-Border Financing and Currency Hedging After Tax Reform

Presented by Pepper Hamilton and Financial Executives Alliance

Steven D. Bortnick, a partner in the Tax and Estates Practice Group of Pepper Hamilton, will be joining John Frey, Managing Director of Foreign Exchange at First Republic Bank, for a webinar on "Cross-Border Financing and Currency Hedging After Tax Reform."

Key topics include:

  • Rules triggering taxable distributions as a result of guarantees by, and pledges of, controlled foreign corporations after tax reform
  • Why changes in stock attribution rules are likely to bring more financing structures into the deemed distribution rules
  • Why planning around CFC guarantees and pledges still is important after GILTI
  • Specific products to hedge exposure to foreign currency on loans
  • Tax treatment of certain hedging activities.
Webinar Documents

Cross-Border Financing and Currency Hedging After Tax Reform Presentation Slides (.pdf)

Webinar Links

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