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Hedge Fund Taxation & Compliance Forum Hedge Fund Taxation & Compliance Forum

June 18 - 20, 2008 | The Flatotel N.Y., New York, NY

Agenda Day Three

Agenda Day Three

Friday, June 20, 2008

8:00 Closed-Door Breakfast: HEDGE FUND ETHICS

Open Exclusively to Attorneys, General Counsel and Compliance Officers

- Rosemary Panelli, CEO, CounselorWorks LLC
8:15 Morning Coffee
8:45 Chairman’s Opening Remarks
9:00 LEGISLATIVE UPDATE FROM THE HOUSE OF WAYS & MEANS

Examination of Congressional Legislative Landscape: Newly Proposed & On The Horizon

  • Interpretation and rationale on proposed legislation
    • Revenue procedure 2007-59
    • IRS Notice 2007-71
    • IRS Section 6694
    • Tax treatment of carried interest for fund managers
  • Insight and assessment of congressional agenda for hedge fund regulation
  • Analysis on what types of legislation need to be enacted and why
  • Best methods for approaching new financial reporting standards
- Charlie Rangel, Chairman, House of Ways and Means Committee, Pending Confirmation
- John Buckley, Chief Tax Counsel, House of Ways and Means Committee, Pending Confirmation
9:45 IRS INSIGHT

Covering Your Bases: A Comprehensive Guide to Managing Increased IRS Scrutiny of Hedge Funds

Analysis of the probe for hedge fund tax abuses from former IRS key players
  • Discover the scope of congress hedge fund inquiry in order to mitigate your risk exposure
  • Examine the areas of potential abuse to avoid enforcement and penalties
    • Timing and allocation of incentive payments
    • Structuring of cross-border loans and tax withholdings
    • Correct accounting methods that report for all income
    • Properly filing tax returns
    • Classification of ordinary income as capital
    • Flow of funds between onshore and offshore entities
    • Disparate treatment of total return swaps
- Matthew Stevens, Partner - International Tax Group, Alston & Bird LLC
   From 2002 to 2004, Matthew served as Special Counsel to the Chief Counsel for the Internal Revenue Service

- Dale Collinson, Director – Financial Institutions & Products, KPMG Washington National Tax
   From 2000 to 2006, Dale was a Special Counsel, Financial Institutions and Products, at the Office of Chief Counsel, for the Internal Revenue Service
10:45 Networking and Refreshment Break
11:15 Technology Showcase: Discover optimal solutions for managing complex tax & compliance functions to maximize middle and back-office efficiency

Companies must consider need to automate processes & workflows that until now have been managed primarily through manual procedures & spreadsheet applications. Evaluate systems to discover those best fit for the needs of your fund.
  • Enterprise-class solutions for handling complexities regulators have added to corporate tax & compliance functions
  • Identifying areas of tax & accounting limitations in your workflow and their associated implications and impact on other functions
  • Determining appropriate systems for implementation: Criteria to look for in technology for addressing your workflow deficiencies
If you are a provider and are interested in participating in this showcase to reach this audience, please contact Susan Feigenbaum at sfeigenbaum@iirusa.com or (646) 895-7478
12:00 Tax Outlook for 2008 & Beyond: Issues on the Horizon

With elections imminent and potential legislative changes, it is critical to assess the tax enviroment and what can be expected.
  • Analyzing the potential effect of the elections and major political changes on your tax position and overall income
  • Assessing the impact on firms of movement for a unitary tax system
  • Latest federal and state tax initiatives affecting funds
  • Concentration on California & New York state tax issues
- Allison Rosier, Senior Tax Manager, PricewaterhouseCoopers LLP
- David Shapiro, Senior Counsel, Office of Tax Policy, Department of the Treasury
1:00 Conference Concludes

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