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Miami Region & YIN Webinar: Loss Limitation Rules in the Cross-Border Context
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Miami Region/YIN Webinar: Loss Limitation Rules in the Cross-Border Context September 17, 2020

When: Thursday, September 17th
11:50 am - 12:30 pm
Where: Virtual
United States
Contact: IFA USA

Online registration is closed.
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Loss Limitation Rules in the Cross-Border Context
Thursday, September 17, 2020
11:50 am – 01:30 pm EDT
10:50 am – 12:30 pm CDT
09:50 am – 11:30 am MDT
08:50 am – 10:30 am PDT




The presentation will survey the rules that could prevent multinational corporations and investment funds/partnerships from fully recognizing or utilizing losses incurred in cross-border transactions. The presentation will include a discussion of (1) the newly issued Section 163(j) Regulations as applied in the cross-border context, (2) the section 267A anti-hybrid rules, (3) the section 250 loss limitation rule as applied to GILTI and FDII, and (4) the rules governing GILTI tested losses. The interaction of loss carryover rules and the CARES act also will be considered. 


Mindy Herzfeld, University of Florida, Gainsville, and Ivins Phillips & Barker, Washington DC

Panelists: Witek Jurewicz,  DLA Piper, New York, NY
Zackary Pullin, Sidley, Houston
Hans Tanzler, PwC, Washington National Office, International Tax Manager, Washington, DC
Brett York,  U.S. Treasury (invited)
Brenda Zent, U.S. Treasury (invited)


This webinar is free for IFA USA members

Non member rate: $25

Please note that the registration process will be in two steps. First, purchase your pass on our website by clicking the Register  button above. After you complete your registration, you will receive an invitation from the Zoom platform where you will need to complete your registration for the live virtual event.

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