Advanced Corporate Finance and International Tax - Course Two

26-27 August 2010
London, UK

This course introduces the general principles and reviews examples of Structured Finance cross-border investment and funding tax arbitrage transactions.

The Course is an advanced review of cross border corporate finance tax issues, structuring and international tax planning, and will focus on structured finance and tax arbitrage opportunities. The transactions reviewed include cross-border sale and repurchase transactions (repos), foreign tax credit and exempt income structures. They also include tax arbitrage using hybrid securities and entities, US entity classification ‘check the box’ structures, the use of revenue and capital losses, tax spared loans, tax capacity and tax capacity transfers, hybrid capital and withholding tax arbitrage.

The course reviews related tax planning opportunities in several jurisdictions including the United Kingdom, the United States, Denmark, France, Germany, Italy, Luxembourg, The Netherlands, Sweden, Switzerland, and Australia. It also reviews opportunities for tax planning using similar structures in other countries.

It is a follow on course from Corporate Finance - Course One. Course Two can be taken immediately following Course One, or it can be taken separately. The emphasis is on practical international tax planning structures at a more advanced level, and includes specific examples, case studies and group discussions.