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2015 Annual Conference Agenda
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2015 Annual Conference

43rd Annual Conference of the USA Branch of the International Fiscal Association
February 26-27, 2015
Washington, DC

 

The event includes two full days of substantive sessions on international tax topics, featuring prominent speakers from private practice, industry, and government. In addition, the event will include two luncheons and a gala dinner with entertainment by The Capitol Steps.

 

A special pre-conference session for the Young IFA Network (YIN) will be held on Wednesday afternoon, followed by a cocktail reception. There is no additional fee for this session and all YIN members are welcome to attend. Registration for the main conference is encouraged, but not required, to attend this special YIN pre-conference session. Use the conference registration form to register for this YIN session.

 

Agenda

 

Wednesday February 25, 2015

 

 

 

4:00 –
5:30 p.m.
YIN Preparatory Session
This session will also be offered as a webinar to members who are unable to attend in person.
The YIN Preparatory Session is intended to provide less experienced practitioners with an introduction to certain technical concepts that will be explored in great depth at the IFA Annual Meeting. Specifically, the session will include introductions to foreign tax credits; the application of the earnings stripping rules under section 163(j) of the Code; and the rules governing “inversion” transactions under sections 367 and 7874 of the Code. In addition to providing a technical background, the session will explore recent developments in these areas at a high level.

 

 

Chair:

Taylor M. Kiessig, Sutherland

Panelists:

Daniel McCall, Special Counsel to the Deputy Associate Chief Counsel (International), IRS
Stephen M. Massed, KPMG

 

 

 

5:30 –
6:30 p.m.
YIN Cocktail Reception

 

 

 

Thursday February 26, 2015

 

 

 

7:30 –
8:30 a.m.
IFA USA Branch Council Breakfast

 

 

 

7:30 –
8:30 a.m.
Registration & Morning refreshments
Sponsored by Economics Partners

 

 

 

8:50 –
9:05 a.m.
Welcome Remarks
Carol P. Tello, Regional Vice President, D.C. Region, IFA U.S.A. Branch
Edward C. Osterberg Jr., President IFA U.S.A. Branch
Porus Kaka, President Central IFA

 

 

 

9:05 –
10:30 a.m.
Assessing the EU State Aid investigations – What are US multinationals doing and what should they be doing?
Sponsored by PwC

This Panel will address the current and ongoing focus in the EU of whether certain taxpayer specific rulings and/or specific tax regimes constitute prohibited State Aid. Hardly a day goes by that this topic is not in the business press, and it has caused multinationals and their advisors to review structures and planning that would have been considered routine just a few years ago. What are the structures of potential concern, how is the EU framing this issue, what should companies and their advisors do in response to existing structure and planning for the future? These and other questions will be addressed with a panel of U.S. and EU professionals and executives.

 

 

Chair:

Nicholas J. DeNovio, Latham & Watkins

Panelists:

Patrick Brown, The General Electric Company
T. Timothy Tuerff, Deloitte Tax
Stef van Weeghel, PwC, Netherlands
Jill Weise, Duff & Phelps

 

 

 

10:30 –
11:00 a.m.
Refreshment Break
Sponsored by Bloomberg BNA

 

 

 

11:00 –
12:00 p.m.

Analysis of the new BEPS discussion drafts and consultations – is anything going to come of this? Almost assuredly, yes.

The OECD’s work on its BEPS project continues, but countries are already implementing the BEPS recommendations and proposing other BEPS-inspired changes to the cross-border tax rules. This panel will discuss the OECD’s latest BEPS discussion drafts and examine various country’s attempts at implementation.

 

 

Chair:

Manal Corwin, KPMG

Panelists:

Brian Jenn, Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury
Marjorie Rollinson, Deputy Associate Chief Counsel (International-Technical), Office of Associate Chief Counsel (International), IRS
Charles Triplett, Mayer Brown

 

 

 

12:15 –
1:45 p.m.
Lunch and Government Speaker
Sponsored by:
Orrick
Government speaker: Robert B. Stack, Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury

 

 

 

2:00 –
3:00 p.m.
Treaty Issues – PE, treaty abuse, dispute resolution, new Competent Authority procedures

Treaties: BEPS-Driven Conceptual Changes and Dispute Resolution Needs: BEPS Action 6 ("Preventing the Granting of Treaty Benefits in Inappropriate Circumstances") and Action 7 ("Preventing Artificial Avoidance of PE Status") contemplate controversial changes to certain conventional treaty approaches. The panel will explore the goals and potential reach of the proposals. In addition, OECD and IRS efforts to revamp the Competent Authority process to more efficiently and effectively handle burgeoning cross-border disputes will be addressed.

 

 

Chair:

Patricia Gimbel Lewis, Caplin & Drysdale

Panelists:

Rocco Femia, Miller & Chevalier
Quyen Huynh, Associate International Tax Counsel, U.S. Treasury
David L. Lundy, Assistant Branch Chief, Branch 1, Office of Associate Chief Counsel (International), IRS
Amy Roberti, Procter & Gamble

 

 

 

3:00 –
3:30 p.m.
Refreshment Break

 

 

 

3:30 –
4:30 p.m.
Latest on inversions – Where are we now?

This panel will explore the latest developments in so-called "inversion" transactions involving U.S. companies combining with smaller foreign merger partners. The panelists will discuss the recent trends in these transactions and the response by the IRS and Treasury Department in Notice 2014-52, seeking to curb certain tax benefits of such transactions, as well as the prospects for additional guidance.

 

 

Chair:

Eric B. Sensenbrenner, Skadden

Panelists:

Peter H. Blessing, KPMG
John J. Merrick, Special Counsel to the Associate Chief Counsel (International), IRS
Joshua D Odintz, Baker & McKenzie
Brenda Zent, Taxation Specialist, Office of the International Tax Counsel, U.S. Treasury

 

 

 

4:30 –
5:30 p.m.
Corporate VP Panel

Corporate Tax VPs: What Keeps Them Awake At Night? A panel of corporate tax leaders will discuss the biggest issues they face right now – and what they are doing to respond. Highlights:

  • BEPS (of course)
  • Increasingly aggressive foreign tax audits, especially for transfer pricing
  • US tax reform and the uncertain fate of tax "extender" provisions
  • Communicating tax risks to company management
  • Managing outside advisors (and finding the best ones)

 

 

 

Chair:

Peter Barnes, Duke University

Panelists:

Patrick Brown, The General Electric Company
Stuart Ison, Corning Incorporated
Charlie Middleton, Oxbow Corporation
Paul Nolan, McCormick & Company

 

 

 

5:45 –
6:45 p.m.
WIN (Women of IFA Network) Reception

 

 

 

6:15 –
7:00 p.m.
RVP (IFA USA Regional Vice Presidents) Reception

 

 

 

6:45 –
10:00 p.m.
Reception, Dinner and Entertainment by The Capitol Steps
Sponsored by:
Covington & Burling
First Names Group
 

 

 

 

Friday February 27, 2015

 

 

 

7:00 –
8:30 a.m.
Sponsor Breakfasts and Presentations
Presented by:
Economics Partners

 

 

 

8:30 –
9:30 a.m.
Foreign Tax Credit Panel

This panel will discuss the following: Foreign tax credit guidance under section 901(m); Finalization of expired and expiring regulations; Recent judicial decisions; Proposed legislative changes.

 

 

Chair:

John L. Harrington, Dentons

Panelists:

Barbara Felker, Chief, Branch 3, Office of Associate Chief Counsel, IRS
Carol P. Tello, Sutherland
Philip Wagman, Clifford Chance

Jason Yen, Attorney Advisor, Office of International Tax Counsel, U.S. Treasury (invited)

 

 

 

9:30 –
10:30 a.m.
Limitations on Deductions in a BEPS and Inversions Environment

The panel will examine the current focus on addressing the potential for base erosion through limitations on deductions for interest and other expenses. Focus areas for the panel will include the policy and technical considerations with respect to:

  • Current-law US approaches to limiting expense deductions
  • Administration proposals for limiting interest and other deductions
  • Legislative proposals for limiting interest deductions
  • OECD BEPS Action 4 on limiting deductions for interest and other financial expenses

The panel will also consider the experience of other countries around the world with respect to limitations on expense deductions, including new limitations taking effect in 2015.

 

 

Chair:

Barbara M. Angus, Ernst & Young

Panelists:

Mark Erwin, Chief, Branch 5, Office of Associate Chief Counsel, IRS
Johanna Hey, Universität zu Köln and Guest Professor New York University
Douglas Poms, Senior Counsel, Office of International Tax Counsel, U.S. Treasury
Peter van Dijk, Head of Tax, TD Bank, Toronto

 

 

 

10:30 –
11:00 a.m.
Refreshment Break

 

 

 

 

 

11:00 –
12:00 p.m.
The Present and Future of Audits and LB&I

This panel will discuss LB&I's initiative to “reinvent” the examination process, including the several complementary elements of that strategy: up-front, selective issue identification; the new IDR process; what makes for a quality examination; the roles of compliance, counsel and Appeals; and litigation strategy. The panel will explore the challenges facing LB&I and the potential implications of the initiative for taxpayers and advisers.

 

 

Chair:

Samuel M. Maruca, Covington

Panelists:

Kevin L. Kenworthy, Miller & Chevalier
Nicolas Kory, Senior Tax Counsel - Controversy, IBM
Sharon Porter, Acting Director, International Business Compliance (LB&I), IRS

 

 

 

12:15 –
12:35 p.m.
USA Branch Reporters for Basel Congress

Subject 1: Tax incentives on Research and Development (R&D)
Subject 2: The practical protection of taxpayer's fundamental rights

 

 

 

12:35 –
1:45 p.m.
Lunch and USA Branch General Meeting
Sponsored by:
Thomson Reuters
Presentation of IFA USA Branch Writing Prize
Luncheon speaker: Porus F. Kaka, President, Central IFA

 

 

 

2:00 –
3:00 p.m.
Unchecking the Box – You thought it was simple? The Not So Simple Answer

The session covers the treatment of existing debt and licenses, whether the transaction qualifies under 351, transferred intangibles, boot, DCLs, OFLs, reporting issues, 901(m) and other relevant matters.

 

 

Presenter:

James P. Fuller, Fenwick & West

 

 

 

3:00 –
4:00 p.m.
Government Roundtable: Hear what government officials are thinking about current tax issues

Hear what government officials are thinking about international tax reform, IRS international guidance priorities, tax treaties, and tax developments outside the United States.

 

 

Chair:

David G. Noren, McDermott Will & Emery

Panelists:

Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation
Steven A. Musher, Associate Chief Counsel (International), IRS
Danielle E. Rolfes, International Tax Counsel, U.S. Treasury

 

Sponsors are Welcome!

View the Sponsorship Information for the 2015 Conference
For sponsorship and exhibiting opportunities, please contact: Michael Davis, michaeld@ifausa.org or call (604)739-4653.

 

 

 

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