b'the A g e n d a 1:20 pm2:30 pm GILTI and Other Anti-Deferral DevelopmentsChair: Amanda P. Varma Partner, Steptoe & Johnson LLP Panelists:Rafic H. Barrage Partner, Baker & McKenzie LLP Michael J. Caballero Partner, Covington & Burling LLPElizabeth C. Lu Partner, McDermott Will & Emery LLP Paul J. Crispino Attorney Advisor, US Department of the TreasuryMelinda 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 foreigncorporations by domestic partnerships ILM 202203013/section 956 anti-abuse rule Other GILTI and subpart F developments PFIC and PFIC reporting developments2:35 pm3:35 pm Cross-Border FinancingChair: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 ServiceErika W. Nijenhuis Senior Counsel, US Department of the TreasuryThe 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 involvingCFC debtors Navigation of BEAT exposure arising from related party debt Role of implicit support in determining guarantee fees or intercompanyinterest rates Continuing relevance of section 956 Potential impact of new corporate book minimum tax3:35 pm3:50 pm 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.6 The Agenda'