D.C. Bar Financial Products Lunch Panel

December 16, 2014


Washington, D.C.

On December 16, 2014, Cleary Gottlieb partner Erika W. Nijenhuis was a panelist during the D.C. Bar Financial Products Lunch Panel which explored various issues relating to section 475 and the mark-to-market method of tax accounting.

The panel topics of discussion included:

  • current issues under consideration at the IRS
  • issues relating to what is necessary to qualify as a dealer, including examining CCA 201423019 (January 22, 2014), which addresses dealer status in the context of loan origination and servicing activities that were performed by two separate partnerships in which the taxpayer was a partner
  • issues relating to mismatches between the asset and liability side of a hedged transaction, including potential timing mismatches in connection with structured notes and their hedges