Christopher Ferguson participated in the panel titled "Advising Financial Institutions In Times Of Uncertainty" at the 2019 ABA Taxation Section Midyear Meeting

The passage of the 2017 Tax Act in December 2017 resulted in significant changes to the international tax landscape in the United States. To fully implement the legislation which contains many unresolved issues and unanswered questions, Treasury and IRS are working hard on drafting and issuing regulations that once finalized, are expected to supplement the provisions of the Act.

In the interim, for a period of almost 18 months, financial institutions are expected to operate, plan and comply with provisions which in part are yet to be published (section 7805(b)(2) allows the Treasury to issue regulations up to 18 months from the enactment date of the legislation with an effective date as of the date of the original legislation and without it being considered retroactive). In light of this unique situation, the panel discussed how financial institutions and their tax advisers should operate in times of uncertainty and how to manage and minimize the risks associated.

Moderator: Shay Menuchin, KPMG, Toronto, ON
Panelists: Professor Diane Ring, Boston College Law School, Boston, MA; Chris Ferguson, Kostelanetz & Fink, New York, NY