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:

Manal S. Corwin Principal in Charge of Washington National Tax, KPMG LLP

Panelists:
Robert B. Stack Managing Director, Washington National and International Tax,
Deloitte Tax LLP

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

John E. Hinding Director of Cross Border Activities, LB&I, Internal Revenue Service

Deborah Palacheck Director of Withholding, Exchange and Individual International Compliance, LB&I, Internal Revenue Service

  • Transfer pricing key areas of interest

  • Competent Authority

  • CAP and APAs best practices

  • Withholding agents

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.
 

10:45 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, 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, 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, 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, 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”s


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, 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 17, 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, 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

Lara Banjanin, Senior Counsel, Branch 1, 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

 

 

 

 

 

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