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