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Tax Section 2010 Annual Meeting (2010)

This program recording provides detailed discussion on two separate topics:

1. Downturn Tax Issues, which covers the tax consequences to debtors and their creditors of debt restructuring and other workouts, including questions and opportunities raised by new section 108(i), and whether foreign creditors may become subject to U.S. tax on net income by reason of the workout activities of portfolio managers and mortgage servicers in the United States.

Speakers

David S. Miller, Esq. (Chair)
Cadwalader, Wickersham & Taft LLP
—New York City

John Harrell, Esq.
Senior Counsel
Office of International Tax Counsel
Department of the Treasury
—Washington, D.C.

David H. Schnabel, Esq.
Debevoise & Plimpton LLP
—New York City

Linda Z. Swartz, Esq.
Cadwalader, Wickersham & Taft LLP
—New York City

Jeffrey Van Hove, Esq.
Deputy Tax Legislative Counsel
(Tax Regulation)
Department of the Treasury
—Washington, D.C.

2. Transactions: Form, Substance, and Understanding the Limits which surveys recent private letter rulings and various transaction structures, analyzes what determines when the form of a transaction should be respected, examines trends in transactional electivity, and discusses the impact of recent case law and potential codification of economic substance on the characterization of transactions.

Speakers

Karen Gilbreath-Sowell, Esq.(Chair)
Ernst & Young LLP
—Washington, D.C.

William D. Alexander, Esq.
Associate Chief Counsel (Corporate)
Internal Revenue Service
—Washington, D.C.

Kimberly S. Blanchard, Esq.
Weil, Gotshal & Manges LLP
—New York City

Michael A. DiFronzo, Esq.
Deputy Associate Chief Counsel
(International-Technical)
Internal Revenue Service
—Washington, D.C.

Gordon E. Warnke, Esq.
Dewey & LeBoeuf LLP
—New York City

Total MCLE Credits  3.0
Ethics MCLE Credits 0.0

* Each additional person who uses the tapes for MCLE credit must purchase a copy of the “MCLE coursebook.”

The product type below that starts with the letter 'V' is a video online program that you will view and listen to on your computer screen. The program code for each topic that you write on the included MCLE Form only appears on the screen and is not announced by audio.

The product type beginning with the number '8' is an audio-only online program that you may listen to through your computer OR download to a portable media player. You will hear the program codes for the MCLE Form announced by audio during the substantive presentations.

Product Type	Member Price	Non Member Price
Tax Section 2010 Annual Meeting (2010) (This product cannot be used to receive MCLE credit) (CLE CourseBooks) 1875	$40.00	$60.00
+ Tax Section 2010 Annual Meeting (2010) (MCLE credit only if you have access to the course's audio/video/CD recording. You cannot receive MCLE credit from a coursebook alone.) (CLE CourseBooks) 1875M	$60.00	$125.00
* Tax Section 2010 Annual Meeting (2010) (MCLE Audio on CD) D8754	$115.00	$195.00
* Tax Section 2010 Annual Meeting (2010) (CLE on DVD) F8754	$150.00	$220.00
Tax Section 2010 Annual Meeting [Audio] (On-Line Programs) 80875	$85.00	$150.00
Tax Section Annual Meeting (2010) [Video] (On-Line Programs) V8754	$85.00	$150.00