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Sutherland is hosting a Conference for Shareholders of Lloyd’s Corporate Members, May 14-15, 2012 in New York. Presented by Tax Practice Group Partners Jeffrey H. Mace and Linda A. Sciuto, the roundtable presentation, titled "Tax Issues Impacting U.S. Shareholders of Lloyd's Corporate Members," begins with an overview of the U.S. federal income and excise tax consequences of being a Lloyd's Corporate Member, including the interplay between the Lloyd’s closing agreements, the Internal Revenue Code and U.S. income tax treaties. Additionally, the agenda covers:
- The CFC issues that arise in the Lloyd's context, including the timing of subpart F income inclusion and the calculation of E&P;
- Tax planning alternatives and pitfalls, including the ability to waive the protection of a permanent establishment clause under an applicable income tax treaty, structuring member-level reinsurance arrangements, side-car syndicates and issues unique to selling or acquiring a Lloyd's vehicle;
- Current and proposed IRS reporting regimes; and
- The potential impact of Dodd-Frank to the insurance industry and Lloyd’s.
The event, which is designed for in-house attorneys and accountants, is being held at Sutherland's New York Office, located at Grace Building, 1114 Avenue of the Americas, 40th Floor.