| Thursday, February 26, 2009 |
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| 8:00 a.m. |
Registration opens |
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9:00 -
9:15 a.m. |
Welcome Remarks |
| Brainard L. (Skip) Patton, President IFA USA Branch |
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9:15 -
10:30 a.m. |
Tax Treaties |
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+ Click here for an overview of this session
This panel will provide an update on treaty network developments, with consideration of such issues as when services may give rise to a permanent establishment; the treatment of disregarded entities; treaty overrides; and the implementation of treaty arbitration under the MAP.
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Moderator: |
Carol Tello, Sutherland |
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Panelists: |
Peter Barnes, General Electric Company
Jack Bernstein, Aird & Berlis
Government Panelist invited
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10:30 -
10:45 a.m. |
Refreshment Break |
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10:45 -
12:00 p.m. |
Transfer Pricing |
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+ Click here for an overview of this session
This panel will address intangibles migration generally, with a focus on the consequences of “business restructurings,” including the recent OECD draft discussion paper. Cost sharing developments and, if appropriate, any new global dealing guidance will be discussed as well.
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Moderator: |
Mike Patton, Ernst & Young LLP |
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Panelists: |
Mike McDonald, U.S. Department of the Treasury
Manfred Nauman
Tim Reichert, Duff & Phelps
Corporate Panelist invited
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12:00 –
1:30 p.m. |
Luncheon Speaker: Edward D. Kleinbard, Chief of Staff of the Joint Committee on Taxation |
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1:30 -
2:45 p.m. |
International Tax Reform |
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+ Click here for an overview of this session
This panel will discuss what drives investment and how the corporate tax works at the margin. It will also consider the benefits of having a tax system similar to foreign competitors.
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Moderator: |
Nick Giordano |
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Panelists: |
Robin Beran, Caterpillar
John Buckley
Peter Merrill, PricewaterhouseCoopers LLP
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2:45 -
3:00 p.m. |
Refreshment Break |
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3:00 -
4:15 p.m. |
Financially Distressed Companies--The Canadian Perspective |
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+ Click here for an overview of this session
This panel will address the Canadian tax treatment of debt forgiveness and debt "parking," restructuring issues for creditors, foreign currency-denominated debt and worthless and nonperforming debt. The panel will also discuss corporate restructurings, acquisition of control and its impact on losses, suspended and superficial loss rules and loss utilization techniques in the context of specific recent transactions. Comparisons will be drawn to the U.S. tax rules.
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Moderator: |
Susan Klein, Winston & Strawn |
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Panelists: |
Mark Brender, Osler, Hoskin & Harcourt LLP
Elinore Richardson, Borden Ladner Gervais LLP
John Ulmer, Davies Ward Phillips & Vineberg LLP
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4:15 -
5:45 p.m. |
Supply Chain Management |
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+ Click here for an overview of this session
This panel will explore current trends in tax-effective supply chain management. The panel will analyze the impact of the U.S. contract manufacturing regulations on these arrangements and will spend time covering new issues raised by the final regulations. Particular attention will be paid to the definition of substantial assistance and the application of the branch rules.
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Moderator: |
Dan Goff, Xilinx |
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Panelists: |
Frank Ortolani, Lockheed
Alan Richter, General Electric Company
Lowell Yoder, McDermott, Will, & Emery LLP
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5:45 -
6:30 p.m. |
Young IFA Network Meeting |
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6:45 -
10:00 p.m.
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Evening Reception & Dinner |
| Entertainment provided by The Capitol Steps |
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Friday, February 27, 2009 |
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8:00 a.m.
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Registration opens |
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9:15 -
10:30 a.m. |
International Restructuring/Repatriation Strategies |
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+ Click here for an overview of this session
This panel will outline the general needs of and difficulties for multinationals to repatriate cash, particularly in light of the current economic environment. It will examine repatriation structures of varying degrees of complexity. Also, it will review some relatively common transactions which, due to the IRS Tier I Issue program, may come under more intense Exam scrutiny. Recent IRS guidance under sections 956 and 367 will be discussed in these settings.
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Moderator: |
Nicholas J. DeNovio, Latham & Watkins, LLP |
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Panelists: |
Hal Hicks, Skadden Arps Slate Meagher & Flom LLP
Al Paul, Dell
Tim Tuerff, Deloitte
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10:30 -
10:45 a.m. |
Refreshment Break |
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10:45 a.m. -
12:00 |
Foreign Tax Credits |
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+ Click here for an overview of this session
This panel will consider the latest developments regarding the technical taxpayer rule, the voluntary tax regulations, foreign tax credit generator transactions, check-the-box planning involving foreign tax credits, section 905(c), the temporary regulations addressing ODLs, OFLs, and SLLs, and other current topics.
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Moderator: |
Alan Fischl , PricewaterhouseCoopers LLP |
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Panelists: |
Rogers Drew , Procter & Gamble
Barbara Felker , Internal Revenue Service
Dirk Suringa, Covington & Burling LLP
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12:00 -
2:00 p.m. |
Lunch |
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USA Branch General Meeting
Brainard L. Patton, President IFA USA Branch, Presiding
Presentation of 2008 IFA USA Branch Writing Prize
Brainard L. Patton, Boston University, Boston |
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2:00 -
3:15 p.m. |
Accounting for Income Taxes |
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+ Click here for an overview of this session
This panel will address the implications for the multinational’s tax function of the forthcoming migration to international financial reporting standards, including an analysis of the SEC “roadmap.” The panel will also discuss experience thus far under FIN 48.
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Moderator: |
Janice Lucchesi, Akzo Nobel |
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Panelists: |
Bob Adams, Internal Revenue Service
Jim Forhan, KPMG LLP
Corporate Panelist invited
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3:15 -
4:00 p.m. |
International Developments – Annual Review |
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James P. Fuller, Fenwick & West LLP, Mountain View |
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| 4:00 p.m. |
End of conference
(This program is preliminary and is subject to change) |
