Learning Objectives:
•You will be able to define “Safe Harbors.”
•You will be able to discuss the Two Prong Test.
•You will be able to explain Notice 2010-62.
•You will be able to review first and second Economic Substance Directives.
Agenda
Faculty
Gregory N. Kidder
Steptoe & Johnson LLP
- Partner in the Washington office of Steptoe & Johnson LLP, where he is a member of the firm’s Business Solutions Department
- Practice focuses on federal income taxation issues, with particular emphasis on the taxation of corporate entities and cross-border transactions
- Advises clients on structuring corporate transactions, including mergers, acquisitions, and spin-off transactions for large public corporations, as well as closely held businesses
- Advises clients on international issues, including deferral, foreign tax credits, and tax treaty matters
- Assists clients in tax controversy matters, including all stages of the Internal Revenue Service administrative process and in litigation
- Extensive experience negotiating with field agents, appeals officers and district counsel in settling significant audit issues
- J.D. degree, Harvard Law School; A.B. degree, Duke University
- Can be contacted at [email protected] or 202-429-6755
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