Partner Jill Darrow will speak on "Effectively Connected Income" at 9:15 a.m. on Wednesday, May 11. Topics that will be discussed in her presentation include:

  • What is a trade or business activity within the United States?
  • Loan origination through intermediaries
  • PIPE funds investing in equity and debt – when to worry
  • Purchasing debt portfolios – An innocent transaction gone awry
  • FIN 48 – The auditors will catch you even if the tax man doesn’t
  • Don’t forget about the branch profits tax
  • States want their share too