b'9:20 am10:20 am International Tax Examination IssuesChair:Paul DeNard Managing Director, PwC LLP Panelists: Mary E. Monahan Partner, Eversheds Sutherland (US) LLPRosemary Sereti Managing Director, Washington National Tax, Deloitte Tax LLPJohn 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 agents10:20 am10:35 am Break *The Internal Revenue Service 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 sponsor.10:45 am11:45 am Foreign Tax Credit DevelopmentsChair: Brian H. Jenn Partner, McDermott Will & Emery LLP Panelists: Layla J. Asali Member, Miller & Chevalier Chartered Lori Hellkamp Partner, Jones DayDanielle E. Rolfes Partner, Washington National Tax, KPMG LLPTeisha Ruggiero Attorney, Branch 3, Internal Revenue ServiceIsaac Wood Attorney Advisor, US Department of the Treasury Recent foreign tax credit regulations and guidance, and planning optionsForeign tax credits and the new corporate book minimum tax The US foreign tax credit and the OECD Pillars Section 905(c)12:00 pm1:10 pm Luncheon with Address by Douglas ODonnell, Deputy Commissioner of Services and Enforcement, Internal Revenue Service, interviewed by Nikole Flax, Commissioner of LB&I, Internal Revenue Servicehttp://www.tggroup.com/GWUIRSInstitute/ 5'