"Taxation of European & U.S. Cross-Border Financial Products"

Understanding the tax issues relating to structured financial products in Europe and the US

• Date: May 19 & 20, 2008
• Place: Marriott Marble Arch - London

Benefits of attending this conference include:

• Learn the basic building blocks of structured financial products
• Discover the latest U.S. and European tax developments
• Understand the role of tax treaties in structured financial products
• Learn about taxation of derivatives and derivative instruments
• Discover how cross-border leasing and tax depreciation products work
• Find out about the accounting issues as they relate to these products
• Learn about off-balance sheet financing
• Discover foreign tax credits and related products
• Use of hybrid entities and instruments
• Hear perspectives from key European and U.S. speakers
• Network with other industry professionals

• May 19, 2008

8h Registration and Continental Breakfast

9h Co-chair Welcome and Introduction

9h30 Generic Building Blocks

• Instrument classification
• Entity classification

-Helen Buchanan

-Cyril Valentin

Freshfields, Bruckhaus Deringer, London

10h30 Funding Products

• Cross-border repos
• Swaps
• Structured debt and equity

-Niels Groothuizen
KPMG Meijburg & Co., Amsterdam

-Julio Castro
Dewey & LeBoeuf, London

11h30 Break for Refreshments

Sponsored by Dewey & LeBoeuf

11h45 Tax Arbitrage Products

• Withholding tax
• Hedging instruments
• Interest double dips
• Interest deduction structures

-Stephen Weston
Deloitte, London

-Erik de Gunst
Deloitte, London

12h45 Summary and Q&A

13h Welcome Luncheon

Sponsored by De Brauw Blackstone Westbroek

14h Understanding Tax Treaties and Their

• Importance to Financial Products
• Tax sparing credit structures
• Withholding taxes
• Double taxation - residency
• Allocation of interest income
• Permanent establishment rules
• Limitation on benefits provisions

-Ulf Johannemann

-Tobias Tuefel

Freshfields Bruckhaus Deringer, Frankfurt

15h Break for Refreshments

Sponsored by Dewey & LeBoeuf

15h15 Tax Consolidation and Off-Balance Sheet Financings

Use of special purpose entities

• Taxation of securitizations
• Monetization of assets
• ABS
• Conduits
• CDOs & CLOs
• SIVs

-Tom Humphreys
Morrison & Foerster, New York

European Speaker to be Announced

16h15 Taxation of Debt Instruments and

Debt/Equity Issues and Products

• OID and imputed interest
• Convertible debt
• Contingent debt instruments
• Limitations on interest deductions
• Issues in regard to distressed debt
• Thin- Capitalization rules in regard to financial products
• Dividend stripping
• Products for bank regulatory capital requirements

-Richard Larkins
Ernst & Young, Washington, DC

-Graham Williams
Ernst & Young, London

17h15 Summary and Q&A

17h30 Conference Adjourns Gala Cocktail Reception

Sponsored by Allen & Overy

• May 20, 2008

8h Continental Breakfast

8h15 Review of Day One and Preview of Day Two

8h30 Leasing and Tax Depreciation Products

Part 1:  Availability of capital allowances and tax depreciation in various EU countries

Part 2:

• Outbound and inbound leasing
• Opportunities for using allowances in more than one country
• Leasetails and receivables sales

-Miles Walton
Allen & Overy, London

-Mark Middleditch
Allen & Overy, London

-Carlos Albinana
Allen & Overy, Madrid

-Mathieu Vignon
Allen & Overy, Paris

-Steve Hackett
Royal Bank of Scotland, London

10h Regulatory Developments in Regarding

Tax Advantaged Financial Products

• General anti-avoidance rules and anti-abuse rules
• Disclosure and compliance requirements
• Economic substance requirements
• JITSIC, OECD and European community initiatives
• Audits and court cases

-Conor O'Brien
KPMG, Dublin

-Giovanna Sparagna
Sutherland Asbill & Brennan, Washington, DC

11h Break for Refreshments

Sponsored by Dewey & LeBoeuf

11h15 Foreign Tax Credits and Products Used in

Conjunction with These Credits

• Double tax agreements
• Refinancing requirements
• Controlled Foreign Corp and Subpart F issues
• Dealing with capital losses and NOLs

-David Hardy
Osler, Hoskin & Harcourt, New York

-Rens Bondrager
De Brauw Blackstone, Westbroek, Amsterdam

12h15 Summary and Q&A

12h30 Networking Luncheon Sponsored by SFI

13h30 Taxation of Derivatives and Derivative Instruments

• Main financial objectives
• Documentation
• ISDA Master agreement
• Options
• Total return swaps
• Credit default swaps

-Dr. Bernulph von Crailsheim
Dewey & LeBoeuf, Frankfurt

-Stephen Taylor
PricewaterhouseCoopers, London

14h30 Use of Transparent and Pass-Through

Entities and Structures

• Partnerships
• LLCs
• Check-the-Box regulations
• Hybrid entities

-Paul Sleurink
DeBrauwBlackstone, Westbroek, Amsterdam

-Julio Castro
Dewey & LeBoeuf, London

15h30 Accounting Issues in Relation to

Tax Advantaged Financial Products

• Fin 48- Accounting for uncertainty in income taxes (FASB)
• US GAAP vs IFRS
• IASB pronouncements
• IAS 37
• Documentation and support issues

-C.J. Getz
Deloitte, London

16h30 Summary and Q&A

16h45 Conference Concludes

About Our Sponsors:

Allen & Overy LLP is a leading international legal practice with some 452 partners and over 4,900 staff, working in 25 major centres worldwide. Allen & Overy's global tax practice provides a multi-jurisdictional tax advisory service, on a standalone basis or as an integral part of the full legal service. We have 110 corporate tax lawyers, with twelve partners based in London.

De Brauw Blackstone Westbroek is an independent law firm, specialized in providing high-end legal advice in business transactions and commercial litigation. Clients include a large number of leading multinational companies and financial institutions as well as listed companies. For the seventh year in succession De Brauw has ranked first as legal adviser to the 100 largest companies in the Netherlands, with over 40% of them selecting De Brauw as their lead law firm.

Dewey & LeBoeuf LLP is an international law firm with more than 1,400 lawyers in 13 countries. The firm has one of the largest tax departments of any general practice law firm, with more than 100 tax attorneys practicing in all areas of tax law in our global offices. The principal areas of our tax practice include domestic and international transactional tax, financial products, corporate tax planning, insurance, tax controversy and lease financing. We advise on US, UK, French, German, Italian, Polish and Russian tax matters.

Freshfields Bruckhaus Deringer is a leading international law firm with offices across Europe, Asia, Middle East and the U.S. where the firm provides legal advice related to various areas of the law. The firm's work comprises the tax efficient structuring of financial products tailored to match the individual needs of retail and institutional investors within the regulatory framework.

KPMG Meijburg & Co Tax Lawyers is one of the leading tax advisory firms in the Netherlands, in particular in the Financial Services Industry. KPMG Meijburg & Co combines an in-depth knowledge of and experience in the Financial Services market with an excellent worldwide network of specialized KPMG tax professionals, enabling us to deliver tailormade advice on development and execution of cross-border financial products.

About SFI: The Structured Finance Institute's mission is to increase the understanding of the use of complex financial products and services. SFI carries out it's mission by organizing domestic and international conferences and seminars in the US and Europe. SFI is part of the ATLAS Information Group, and together, sponsor more than 50 programs per year throughout the USA, Canada, and Europe.

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