1. • Background of the industry
    • Typical transaction structures
    • Tax characterisation issues
    • Responses of tax authorities
    – United States
    – United Kingdom
    – Other jurisdictions

    # vimeo.com/121872823 Uploaded 28 Plays 0 Comments
  2. • Impact of European AIFM
    • Shadow banking
    • Investment in distressed debt
    • Participating loans
    • Global private equity funds
    • Use of blocker partnerships
    • Royalty funds
    • Derivatives – swaps with up-front payments (deemed loans), foreign currency options, issues for short sales, basket options

    # vimeo.com/121872694 Uploaded 18 Plays 0 Comments
  3. Financing issues including:
    • Crowd funding, peer-to-peer lending, payday lending
    • Impact on financial industry
    • Potential impact of BEPs, PEs, Transfer pricing, IT/IP structures

    # vimeo.com/121872542 Uploaded 28 Plays 0 Comments
  4. # vimeo.com/121872390 Uploaded 9 Plays 0 Comments
  5. • Reconciling IGA, US regulations and local implementation
    • FATCA type legislation in EU
    • Practical implementation issues for countries which signed agreements
    • Consequences of FATCA enforcement (eg, restructure client trusts)

    # vimeo.com/121872322 Uploaded 42 Plays 0 Comments

Tax law

International Bar Association PRO

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