Friday, October 20

2:30PM – 5:30PM

Financial Transactions

Chair: Jeff Maddrey, PricewaterhouseCoopers LLP, Washington, DC

2:30pm             Call Spread Convertibles.  This panel will explore issues arising from so-called "call spread convertible" transactions.  Moderator:  David Garlock, Ernst & Young LLP, Washington, DC.

3:30pm             Recent Developments Regarding Hybrid Instruments and Foreign Tax Credit Planning.  Commissioner Mark Everson recently testified before Congress on IRS concerns with respect to "abusive" foreign tax credit transactions and the use of hybrid instruments in cross-border financing structures.  These issues have also been the subject of increased IRS focus on examination.  This panel will review recent developments with respect to these topics. Moderator:  Chip Harter, PricewaterhouseCoopers LLP, Washington, DC.

4:30pm             Hot Topics and Current Developments.  This panel will address current developments in financial products. Moderator: Richard Larkins, Ernst & Young LLP, Washington, DC.