b'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 complianceissues The existence of a PE as a result of the arrangementswill OECDchange the answer? If a PE, what is profit attribution? Impact on operational tax analysisDEMPE concerns Self-Helpusing a local subsidiary, split payrolls, using a PEO, businessdriven solutions. Is it really a help?10:35 am10:50 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.10:50 am11:50 am EthicsChair: 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, CharteredThrough interactive discussion of case studies, this panel explores the range of ethical issues confronting government and private sector taxprofessionals 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 regardingforeign law and to foreign tax authorities IRS and Treasury international tax rulemaking and policymaking12:00 pm1:15 pm Luncheon with Address by Itai Grinberg, Deputy Assistant Secretary, Multilateral Negotiations, Office of Tax Policy, US Department of the Treasuryhttp://www.tggroup.com/GWUIRSInstitute/ 9'