AGENDA
Thursday, December 15,
2022
Wifi sponsored by
*The Internal Revenue and the US Department of the
Treasury are not sponsoring the Wifi and their participation is not
intended as an endorsement of the sponsors.
7:15 am - 8:00 am |
Breakfast
*The Internal Revenue and the
US Department of the Treasury are not sponsoring the
breakfast and their participation in the breakfast is not intended as an
endorsement
of the sponsors.
|
8:00 am - 8:15 am |
Welcome and Introductions
Dayna Bowen Matthew
Dean and Harold H. Greene Professor of Law, The George Washington
University Law School
Co-Chairs:
Nicholas J. DeNovio
Partner, Latham & Watkins LLP
Robert J. Peroni
The Fondren Foundation Centennial Chair for Faculty Excellence and
Professor of Law, The University of Texas School of Law
Jennifer L. Best
Director of Treaty and Transfer Pricing Operations,
LB&I, Internal Revenue Service
Peter H. Blessing
Associate Chief Counsel (International), Internal Revenue Service
|
8:15
am - 9:15 am |
Global Trends/Competent
Authority/Multilateralism
Chair:
Robert B. Stack
Managing Director, Washington National and International Tax,
Deloitte Tax LLP
Panelists:
Jason Yen
Principal, International Tax and Transaction Services, EY LLP
Jennifer L. Best
Director of Treaty and Transfer Pricing Operations, LB&I, Internal
Revenue Service
Michael H. Plowgian,
Counselor to the Assistant Secretary for Tax Policy, US Department
of the Treasury
Achim Pross
Head, International Co-operation and Tax Administration Division
Centre for Tax Policy and Administration, OECD
-
Current state of multilateral cooperation – The BEPS saga
-
Future of collaboration in aftermath of BEPS
-
The role of treaties in the BEPS journey
-
Convergence of tax and ESG
|
9:20
am - 10:20 am |
International Tax Examination Issues
Chair:
Paul DeNard,
Managing Director, PwC LLP
Panelists:
Mary E. Monahan
Partner, Eversheds Sutherland (US) LLP
Rosemary Sereti
Managing Director, Washington National Tax, Deloitte Tax LLP
Orrin Byrd
Director of Withholding, Exchange and International Individual
Compliance, Internal Revenue Service
Deborah Palacheck
Director of Cross Border Activities. LB&I, Internal Revenue Service
|
10:20
am - 10:35 am |
Break
*The Internal
Revenue and the US Department of the Treasury are not sponsoring the
break and their participation in the break is not intended as an
endorsement of the sponsors.
|
10:35 am -
11:45 am |
Foreign Tax Credit Developments
Chair:
Brian H. Jenn
Partner, McDermott Will & Emery LLP
Panelists:
Layla J. Asali Member, Miller & Chevalier Chartered
Lori Hellkamp Partner, Jones Day
Danielle E. Rolfes Partner, Washington National Tax, KPMG LLP
Teisha Ruggiero
Attorney, Branch 3,
Office of Associate
Chief Counsel (International) Internal Revenue Service
Isaac Wood
Attorney Advisor, US Department of the Treasury
-
Recent foreign tax credit regulations and guidance, and planning
options
-
Foreign tax credits and the new corporate book minimum tax
-
The US foreign tax credit and the OECD Pillars
-
Section 905(c)
|
12:00
pm -1:10 pm |
Luncheon with Address by Douglas
O’Donnell, Deputy Commissioner of Services and Enforcement, Internal
Revenue Service, interviewed by Nikole Flax, Commissioner of LB&I,
Internal Revenue Service |
1:20
pm - 2:30 pm |
GILTI and Other Anti-Deferral
Developments
Chair:
Amanda P. Varma
Partner, Steptoe &
Johnson LLP
Panelists:
Rafic H. Barrage
Partner, Baker & McKenzie LLP
Michael J. Caballero
Partner, Covington
& Burling LLP
Elizabeth C. Lu
Partner,
McDermott
Will & Emery LLP
Paul J.
Crispino
Attorney Advisor, US Department of the Treasury
Melinda Harvey
Branch Chief, Branch 2, Office of Associate Chief Counsel
(International) Internal Revenue Service
-
Selected international tax aspects of
the new corporate book minimum tax
-
Final section 958 regulations on
treatment of ownership of foreign corporations by domestic
partnerships
-
ILM 202203013/section 956 anti-abuse
rule
-
Other GILTI and subpart F developments
-
PFIC and PFIC reporting developments
|
2:35
pm - 3:35 pm |
Cross-Border Financing
Chair
Gary B. Wilcox
Partner, Mayer Brown LLP
Panelists:
J. Brian Davis
Partner, Head of International Tax, Baker & Hostetler LLP
Elena Romanova
Partner, Latham & Watkins LLP
Azeka Abramoff
Special Counsel, Office of Associate Chief Counsel (International) Internal Revenue Service
Erika W.
Nijenhuis
Senior Counsel, US Department of the Treasury
The panel will explore the key threshold questions of where should
US- and foreign-based multinationals locate their external and
internal debt within their organizations, and how should their debt
be structured (including through alternative types of financing) in
light of the many complicated, and often intersecting, rules that
either limit the tax benefits of using debt or increase exposure
under various regimes by virtue of using debt. Topics to be
discussed include:
-
Section 163(j) limits on cross-border or other indebtedness
involving CFC debtors
-
Navigation of BEAT exposure arising from related party debt
-
Role of implicit support in determining guarantee fees or
intercompany interest rates
-
Continuing relevance of section 956
-
Potential impact of new corporate book minimum tax
|
3:35
pm - 3:50 pm |
Break
*The Internal
Revenue and the US Department of the Treasury are not sponsoring the
break and their participation in the break is not intended as an
endorsement of the
sponsors.
|
3:50
pm - 4:50 pm |
Mergers & Acquisitions I “Blocking &
Tackling”
Chair
Eric B. Sensenbrenner
Partner,
Skadden, Arps, Slate, Meagher & Flom LLP
Panelists:
Kara L. Mungovan
Partner, Davis Polk & Wardwell LLP
Joseph M. Pari
Co-Chair, Tax Department, Weil, Gotshal & Manges LLP
Laura Williams
Branch Chief,
Branch 4, Office of Associate Chief Counsel (International) Internal Revenue Service
Brenda L. Zent
Special Advisor on International Taxation, Office of the
International Tax Counsel, US Department of the Treasury
-
Purchase and sale of CFCs
-
International spinoffs
-
Movement of IP
-
Section 338 elections
-
Section 7874 considerations
-
Interaction of Pillar 2 with transactions
-
Considerations related to excise tax on share repurchases
|
4:55
pm - 5:55 pm |
Mergers & Acquisitions II “Private
Investors”
Chair
Rachel D. Kleinberg
Partner,
Sidley Austin LLP
Panelists:
Andrea A. Ramezan-Jackson Partner, Latham & Watkins LLP
Moshe Spinowitz Partner, Skadden, Arps, Slate, Meagher & Flom LLP
Andrew Gordon
Special Counsel,
Office of Associate
Chief Counsel (International) Internal Revenue Service
Jim Wang
Attorney Advisor, US Department of the Treasury
This panel will focus on M&A issues for private investors. Topics
to be discussed include:
-
Regulations under section 897(l)
-
Continuing issues under section 892 and FIRPTA
-
Use of blocker entities
-
Investments in and through partnerships, including section
1446(f)
-
GILTI, subpart F and section 1248 for private investors on sale
transactions
|
6:00
pm -7:00 pm
|
Reception
*The Internal Revenue and the US Department
of the Treasury are not sponsoring the
reception and their participation in the reception is not intended
as an endorsement of
the sponsors.
|
Friday, December
16,
2022
Wifi sponsored by
*The Internal Revenue and the US Department of the
Treasury are not sponsoring the Wifi and their participation is not
intended as an endorsement of the sponsors.
7:30 am - 8:30 am |
Breakfast
*The Internal Revenue and the US Department of the
Treasury are not sponsoring the breakfast and their participation in the
breakfast is not intended as an endorsement of the sponsors.
|
8:30 am - 9:30 am |
Supply Chain Issues
Chair
Rocco V. Femia
Member, Miller & Chevalier Chartered
Panelists:
Patrick Brown
Partner and Co-Leader of Washington National Tax Services, PwC LLP
Colleen O’Neill
US National Tax Department Leader, International Tax and Transaction
Services, EY LLP
Frank “Chip” Dunham
Branch Chief, Branch 6,
Office of Associate
Chief Counsel (International) Internal Revenue Service
Christopher J. Bello
Senior Counsel, US Department of the Treasury
This panel will focus on tax and non-tax developments causing businesses
to reconsider business models and supply chain planning, including:
-
Geopolitical developments affecting location decisions
-
Emerging Pillar 2 rules, including rules related to incentive
regimes and to internal restructurings
-
Extraterritorial taxes and policy responses
-
Recent US tax controversy developments
|
9:35
am - 10:35 am |
Worker Mobility
Chair
Joan C. Arnold
Partner, Troutman Pepper Hamilton Sanders LLP
Panelists:
Mark D. Harris Senior Tax
Counsel, The Coca Cola Company
Joshua D. Odintz Partner, Holland &
Knight LLP
Elizabeth Stevens
Member, Caplin & Drysdale, Chartered
Lara Banjanin,
Senior Counsel, Branch 1,
Office of Associate
Chief Counsel (International) Internal Revenue Service
Mobile (Global) Executives –
Impact and planning. Through a case study, the panel will develop
and explore a framework to analyze the company and individual tax
issues that arise when an employee performs services for a
corporation that is not located in the jurisdiction of the residence
of the employee. We will address substantive tax issues and
reporting and compliance, and will consider a few means of self-help
to manage the issues. Key issues include:
-
Residency of the individual, taxing employment income and
compliance issues
-
The existence of a PE as a result of the arrangements – will
OECD change the answer?
-
If a PE, what is profit attribution?
-
Impact on operational tax analysis – DEMPE concerns
-
Self-Help – using a local subsidiary, split payrolls, using a
PEO, business driven solutions. Is it really a help?
|
10:35 am - 10:50 am |
Break
*The Internal Revenue and the US
Department of the Treasury are not sponsoring the break and their
participation in the break is not intended as an endorsement of the
sponsors.
|
10:50 am - 11:50 am |
Ethics
Chair
Linda
Galler
Max Schmertz Distinguished
Professor of Law, Maurice A. Deane School of Law at Hofstra
University
Panelists:
Diane M. Ring
Interim Dean,
Professor of Law and
Dr. Thomas F. Carney Distinguished Scholar, Boston College Law
School
Christopher S.
Rizek
Member, Caplin
& Drysdale, Chartered
Through interactive discussion of case studies, this panel explores
the range of ethical issues confronting government and private
sector tax professionals in international tax practice and considers
them against the ethical rules (including ABA Model Rules, AICPA
Code and Statements, Circular 230 and Standards of Ethical Conduct
for Employees of the Executive Branch). Topics may include ethical
issues arising in:
-
International tax controversies
-
International tax planning and transactions, including duties
regarding foreign law and to foreign tax authorities
-
IRS and Treasury international tax rulemaking and policymaking
|
12:00
pm - 1:15 pm |
Luncheon with Address by Itai Grinberg,
Deputy Assistant Secretary, Multilateral Negotiations, Office of Tax
Policy, US Department of the Treasury |
1:30
pm - 1:45 pm |
Break
*The Internal Revenue and the US Department of the Treasury are not sponsoring the break and their
participation in the break is not intended as an endorsement of the
sponsors.
|
1:45
pm - 2:30 pm |
Views from the Government
Moderator
Peter H.
Blessing
Associate Chief Counsel (International), Internal Revenue Service
Panelists:
Nikole Flax
Commissioner, LB&I, Internal Revenue Service
Robin
Greenhouse
Division Counsel, LB&I, Internal Revenue Service
Lindsay
Kitzinger
Acting International Tax Counsel, US Department of the Treasury
Charles
Pillitteri
Deputy Division Counsel, SB/SE, US Department of the Treasury
|
Privacy
Policy
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