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Derivative Instruments


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									        COURSE                                                                 ADVANCED LEVEL

IBFD International Tax Academy presents:

The legal, accounting and tax framework of derivative instruments from both a
domestic and international perspective

                                                                                  6 & 7 August

– Derivative instruments will be clearly defined and their applications
– Accounting aspects will be looked at in detail.
– Domestic and international (tax treaties) tax issues will be examined.
– Use of case studies will help develop practical/implementation skills.
– International perspective (course instructors and participants from around
  the world).
– Qualifies for 12.5 Continuous Professional Education (CPE) credits.


IBFD International Tax Academy

IBFD, Your Portal to Cross-Border Tax Expertise
Amsterdam, 6 & 7 August 2007                                                               www.ibfd.org


Why participate?                                             The IBFD International Tax Academy is registered
This course deals with the legal, accounting and tax         with the National Association of State Boards of
aspects of derivative instruments. Particular attention      Accountancy (NASBA), as a sponsor of continuing
is given to the tax treatment of such instruments            professional education on the National Registry of
from a domestic and international tax perspective.           CPE Sponsors. State boards of accountancy have
Participants will acquire a structured background            final authority on the acceptance of individual courses
knowledge of the concepts and principles of derivative       for CPE credit. Complaints regarding registered
instruments. They will learn what to look for when           sponsors may be addressed to the National Registry
dealing with derivatives; the questions to ask; the          of CPE Sponsors, 150 Fourth Avenue North, Suite
issues to solve; the different approaches of domestic        700, Nashville, TN, 37219-2417.
legislations; and how to apply double taxation treaties.     Website: www.nasba.org

This two-day intensive course is divided into two            Recommended CPE points for this course: 12.5
sessions. Session one is dedicated both to the legal         (in accordance with the standards of the National
and accounting treatment of derivatives, whilst session      Registry of CPE points, CPE credits are granted on a
two is wholly focused on the domestic and tax treaty         50-minute hour).
aspects. The course will end with a case study to
enable participants to gain confidence in applying the       Interactive course
skills acquired during the course.                           To safeguard the interactive nature of the course,
                                                             including group discussions and case studies,
Participation is of benefit to:                              a maximum of 30 participants will be accepted.
– lawyers;                                                   Early registration is therefore recommended.
– tax consultants;
– in-house counsel; and                                      Venue
– finance professionals who wish to gain a complete          The course will be held at the IBFD Head Office
  understanding of the subject.                              in Amsterdam, which boasts the latest in teaching
                                                             facilities. This venue also provides participants with
Continuing Professional Education                            the opportunity to visit and undertake research at the
This course qualifies for Continuing Professional            IBFD Library and Information Centre, and offers ample
Education (CPE) credits with:                                opportunity to network and share information with our
– The UK Chartered Institute of Taxation;                    resident research staff as well as with other tax
– De Nederlandse Federatie van Belastingadviseurs;           professionals.
– The Institute of Taxation in Ireland; and
– The National Association of State Boards of                How to register
  Accountancy.                                               Simply fill in your details on the registration form
                                                             included with this brochure and return it to us by post
It should be noted that this course may also qualify         or fax.
for CPE credits pursuant to the rules of a number
of professional associations other than those listed
above. Participants are encouraged to check with their
professional associations to determine eligibility in this

IBFD, Your Portal to Cross-Border Tax Expertise                                                                        2
Amsterdam, 6 & 7 August 2007                                                         www.ibfd.org


Floris Andriessen is a manager in KPMG’s Financial
Services Advisory practice, with a particular focus on
advising clients on financial risk management, financial
accounting and regulatory reporting. His advisory work
includes topics such as IFRS (IAS 32/39) conversion
and risk management framework review at banks
and corporate treasuries. Prior to joining Financial
Services Advisory about 5 years ago, Floris had 3
years experience in auditing financial institutions and
corporate treasuries with the Audit practice of KPMG
Financial Services.

Carmine Rotondaro is Worldwide Tax Manager of
the Gucci Group. He is also managing editor of the
IBFD loose-leaf publication Tax Treatment of Transfer
Pricing and of the IBFD journal Derivatives & Financial
Instruments. Mr Rotondaro is the author of several         Supporting Material
articles in the field of international taxation and a
speaker at various congresses and conferences.             Derivatives and Financial Instruments

Raffaele Russo is a Tax Treaty Advisor at the OECD.        This journal provides authoritative, up-to-
He previously worked as a Senior Associate in the          date information and sharp analyses for tax
IBFD International Tax Academy, Amsterdam, and as a        professionals and financial market experts around
tax lawyer with NCTM Studio Legale Associato, Milan.       the world.
He has a law degree from the University Federico II of
Naples and an LLM in International Taxation from the
                                                           –   Detailed articles on topics concerning the
University of Leiden, the Netherlands. He is the author
                                                               taxation of derivatives and financial
of several publications on international tax matters,
including the IBFD’s best-seller The Attribution of
                                                           –   Different perspectives are provided in
Profits to Permanent Establishments, and speaks
                                                                substantial country surveys written by
regularly at seminars and conferences.
                                                                respected local specialists.
Roger Smith is a Senior Trader on the Structured           –   Input from OECD and other countries ensures
Products desk at Cantor Fitzgerald Europe in London.           that coverage is truly global.
He graduated from Ohio University in 1990 and has
worked in the European banking and finance sector for      Format:                 online or print
over 15 years. Before joining Cantor, he traded FX and     Free trial available:   yes
money markets for Rolo Banca in Italy, repurchase          Further information:    www.ibfd.org
agreements for Unicredito Italiano in Luxembourg,
and interest rate products for Bank of America and JP      Price:                  € 430 / $ 555 (online, for
Morgan Securities in London.                                                       up to 5 users)
                                                                                   € 460 / $ 590 (print,
                                                                                   published bimonthly)

                                                                                   20% discount for ITA
                                                                                   course participants

IBFD, Your Portal to Cross-Border Tax Expertise                                                                 3
              Amsterdam, 6 & 7 August 2007                                                   www.ibfd.org

              Programme                                                                       The programme fee includes
                                                                                              lunch, coffee, tea and light
                                                                                              refreshments during breaks.

              Day 1                                                       Day 2

08.30-09.00   Registration                                  09.00-11.00   Domestic Tax Law Aspects of Derivatives
                                                                          – Characterization
09.00-09.15   Welcome and IBFD Overview                                   – Deductibility
                                                                          – Timing
09.15-10.00   Introduction                                                – Withholding tax
              – The concept of derivative instrument                      – Anti-avoidance rules
              – Legal, accounting and tax framework
                                                            11.00-11.20   Break – coffee/tea and refreshments
10.00-10.40   Main Types of Derivatives
              – Commodities and financial derivatives       11.20-12.45   Tax Treaty Aspects of Derivatives
                 – futures                                                – Characterization
                 – options                                                – Art. 7 (Business Profit)
                 – swaps                                                  – Art. 11 (Interest)
              – Credit Derivatives                                        – Art. 13 (Capital Gains)
                 – credit default swap                                    – Art. 21 (Other Income)
                 – credit-linked note                                     – Timing issues
              – Equity Derivatives
                 – equity swap                              12.45-14.00   Lunch
                 – total rate of return swap
                                                            14.00-15.00   Tax Treaties Aspects of Derivatives
10.40-11.00   Break – coffee/tea and refreshments                         (continued)

11.00-12.45   Main Types of Derivatives (continued)         15.00-15.20   Break – coffee/tea and refreshments

12.45-14.00   Lunch                                         15.20-17.00   Case Study

14.00-15.10   Overview of Tax Issues of Derivatives

15.10-15.30   Break – coffee/tea and refreshments

15.30-17.00   Accounting Treatment of Derivatives
              – Hedging v. trading
              – Mark-to-market and fair value measurement
              – Unrealized gains and losses
              – Current income

              IBFD, Your Portal to Cross-Border Tax Expertise                                                                4
Amsterdam, 6 & 7 August 2007                                                               www.ibfd.org


About the IBFD                                               Registration details
Since its foundation in 1938, the International Bureau
of Fiscal Documentation has developed into one               Venue
of the most respected organizations studying and             IBFD Head Office
documenting international taxation systems and               H.J.E. Wenckebachweg 210
investment legislation. IBFD clients include Ministries      1096 AS Amsterdam
of Finance, international corporations, legal and            The Netherlands
accountancy practices, banks, educational institutions
and others who look to the IBFD as a first-class
source of information. As an independent, not-for-           Member discount
profit research foundation, the IBFD always offers           IBFD members qualify for a 20% discount on the fees
objective and unbiased information. A multilingual           of all open courses held by the IBFD International Tax
staff of approximately 50 tax experts from around            Academy. Companies with several offices, please note
25 countries is based in the IBFD Amsterdam                  that – as with all membership offers – only staff based
Head Office. In addition, research is carried out            at the office that actually holds the membership, i.e.
internationally, with a network of tax specialists           the address publications and correspondence are sent
relaying information from all over the world.                to, qualify for the 20% discount.

IBFD International Tax Academy
Founded in 1989, the International Tax Academy               Accommodation
(ITA) offers a wide range of courses on international        Participants are responsible for making their own
taxation and organizes conferences on special topics.        arrangements.
The ITA is recognized worldwide as a reputable
learning centre in the field of international taxation,      Bank details
drawing on the expertise of internationally renowned         IBFD International Tax Academy
specialists and the IBFD multinational research staff        ING Bank N.V.
to provide a unique environment for the study of             Amstelplein 1
international tax law.                                       1096 HA AMSTERDAM
                                                             The Netherlands
The open courses held by the ITA are interactive and         Account No. 65 01 66 361
suitable for participants from all over the world. The       Swift Code: INGBNL2A
ITA also offers tailored in-house courses for corporate
clients, tax administrations and other organizations         IBFD International Tax Academy
and institutions. If you would like to discuss any           P.O. Box 20237
aspect of our in-house courses, please contact Arcotia       1000 HE Amsterdam
Hatsidimitris, Head of ITA, either at +31-20-554 0180        The Netherlands
or e-mail A.Hatsidimitris@ibfd.org.                          Tel.: +31-20-554 0160
                                                             Fax: +31-20-620 9397
IBFD Library and Information Centre                          E-mail: itacourses@ibfd.org
ITA course participants are free to use the IBFD’s           Website: www.ibfd.org
Library and Information Centre whilst they are in
Amsterdam. The library houses the largest collection
of titles (both print and electronic) on international and
comparative taxation anywhere in the world. During
their stay the library is happy to provide participants
with a workstation, computer and librarian services
free of charge.

IBFD, Your Portal to Cross-Border Tax Expertise                                                                        5
   Registration Form                                                                                                (please use block letters)

I would like to register for the course:
O Derivative Instruments
    Date: 6 & 7 August 2007 Code: OC07DER1 Normal fee: € 1,360 / $ 1,632 Members’ fee: € 1,088 / $1,306*
    * Clients in the Americas will be invoiced in US dollars.
O Mr O Mrs
                                                                          (as it is to appear on your name badge)      Cancellation and other
First name                                                                                                             registration conditions
                                                                          (as it is to appear on your name badge)      You may be prevented from attending a
O I have full IBFD membership (20% discount)                                                                           course due to unforeseen circumstances.
                                                                                                                       If you notify us in writing of your cancellation
My membership number is                                                                                                at least 14 days prior to the event, no
                                                                                                                       cancellation fee will be charged, except for
Organization                                                                                                           an administration fee to cover the cost
                                                                                                                       of processing the cancellation. If
Job title                                                                                                              notification is received within 7 to 14 days
                                                                                                                       before the event, a cancellation fee of 50%
Address                                                                                                                of the course fee will be charged. We regret
                                                                                                                       that no refunds can be made if notice of
City and postal code                                                                                                   cancellation is received less than 7 days
                                                                                                                       before the event. An alternative participant
Country                                                                                                                may be substituted at any time without
                                                                                                                       charge provided that the IBFD International
                                                                                                                       Tax Academy is informed in advance of the
Telephone                                                        Fax                                                   event. The IBFD International Tax Academy
                                                                                                                       reserves the right to cancel an event if there
                                                                                                                       is an insufficient number of registrations, in
                                                                                                                       which case our liability shall be restricted to
VAT No.                                                                                                                a refund of any course fees paid to us.
                                                                                                                       Cancellation notices will be sent at least
                                                                                                                       14 days in advance of the event. The IBFD
Signature                                                               Date                                           International Tax Academy also reserves
                                                                                                                       the right to alter published programmes
                                                                                                                       and speakers without notice.

                                                                                                                       On receipt of your registration
                                                                                                                       You will receive a confirmation letter and
                       (Please note that only signed forms can be processed)                                           an invoice. Whenever possible we will
                                                                                                                       use e-mail for correspondence in order
                                                                                                                       to communicate effectively and quickly.
                                                                                                                       Please contact us if you have not
                                                                                                                       received the confirmation letter within 10
Contact person responsible for training within your organization:                                                      days of sending your registration form.

Name                                                                                                                   Please visit our website (www.ibfd.org)
                                                                                                                       for full details of our booking information.
Function                                                                                                               For more detailed information about our
                                                                                                                       courses or to register you can also call us at
Telephone                                                                                                              +31-20-554 0100, e-mail itacourses@
                                                                                                                       ibfd.org or visit our website at www.ibfd.org.

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                                                                                                                       by regular mail or fax to:
If the invoice address differs from the above, please indicate:                                                        IBFD International Tax Academy
                                                                                                                       P.O. Box 20237
Organization                                                                                                           1000 HE Amsterdam
Attention to                                                                                                           The Netherlands
                                                                                                                       Tel.: +31-20-554 0160
Address                                                                                                                Fax: +31-20-620 9397
                                                                                                                       E-mail: itacourses@ibfd.org
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