Philip Cook, Matthew Stevens and Andy Immerman spoke on a panel for lunch and a one-hour overview of some of the most pressing federal and international tax issues. This event was hosted at the offices of Alston & Bird LLP.
Developments discussed were:
• The disclosability of tax accrual workpapers, including the impact of FIN 48 and the Textron decision and potential changes in the IRS policy of restraint
• Congressional efforts to obtain FIN 48 information
• The proposed codification of the economic substance doctrine and its effect on normal business transactions
• The patenting of tax strategies
• The controversy over carried partnership interests
• International developments relating to foreign tax credits, allocation of interest expense, and controlled foreign corporations
Tuesday, November 27, 2007
11:30am - 1:00pm
Alston & Bird LLP / 1180 West Peachtree Street / Atlanta, GA