Winston & Strawn partner Susan Klein, who is based in the firm's New York office and concentrates her practice in taxation and international transactions, moderated a panel discussion during the 37th Annual Conference of the USA Branch of International Fiscal Association (IFA) held February 26-27, 2009 in Washington, D.C.
Ms. Klein, who recently completed a term as Vice-President Secretary of IFA's U.S. Branch, moderated a panel discussion titled "Financially Distressed Companies – The Canadian Perspective." The panel addressed the Canadian tax treatment of debt forgiveness and debt "parking," restructuring issues for creditors, foreign currency-denominated debt and worthless and nonperforming debt. Special focus was placed on corporate restructurings, acquisition of control and its impact on losses, suspended and superficial loss rules and loss utilization techniques in the context of specific recent transactions. Comparisons were drawn between the Canadian and U.S. tax rules.
Joining Ms. Klein on the panel were Mark Brender from Osler, Hoskin & Harcourt; Elinore Richardson of Borden Ladner Gervais; and John Ulmer with Davies Ward Phillips & Vineberg LLP.
The IFA annual conference brings together government policy-makers and practitioners from both private practice and industry to share their insights, judgment, and experience in the following areas of international tax law and practice:
- Business Restructurings and Intangibles Migration
- What International Tax Reform Might Look Like
- International Restructuring and Repatriation Strategies
- Current Developments in the Foreign Tax Credit Regime