Day two walked through several panels and keynote addresses revolving around tax administration and dispute resolution. Jerry Libin's keynote explored "Enhanced Relationships Between Tax Authorities and Taxpayers: Myth or Reality." This was followed by panels on "US APA Program: History, Operation, Effectiveness" and "Comparative Dispute Resolution and Avoidance Measures," and concluded with a lunch-time keynote on "Tax Treaties" by David Tillinghast. Friday afternoon devoted two hours to " Special Topics in Transfer Pricing."

The US and Indian IFA Branches first met in joint conference on January 23-25, 2006, in New Delhi. At that time, members of IFA-USA seemed most interested in gaining a better understanding of the Indian tax system, getting to know some of the most prominent Indian tax practitioners, and in gaining some small footing to influence the development of Indian tax policy - which many believed to be quite inhospitable. The Indian system of tax administration seemed biased, bureaucratic, and slow. The USA practice of dispute resolution, particularly an APA program for resolving inter-company transfer pricing disputes, was not available in India.

Small steps have been taken and, as mentioned above, the 2009 DC conference included a panel on APA's. Indian promoters of an annual conference in India have requested that a similar panel, with many of the same participants, be given at the 2009 Mumbai Conference coming up this December. As an optimistic development, the Indian Budget proposed, on July 6, to create an alternative dispute resolution mechanism for transfer pricing and to formulate safe harbor rules to use in auditing cross-border inter-company pricing. This will not be the "perfect" solution but certainly is an excellent step forward, and one which in no small part can be attributed to positive efforts like the ones initiated by IFA-USA through its joint IFA conferences with the Indian Branch and relationships developed there.

And early plans are already being discussed for the nest India-USA Conference, probably in Delhi in 2012. So stay tuned.

Thanks go to the Organizing Committee including the Chair Roger D. Wheeler, KPMG LLP, Charles Cope, KPMG LLP, Jeffrey A. Levenstam, Ernst & Young LLP, Sam Maruca, Covington & Burling LLP, and Carol P. Tello, Sutherland Asbill & Brennan LLP. The Program Committee from the USA included: Joan C. Arnold, Pepper Hamilton LLP
Peter A. Barnes, General Electric Company, Simon Beaumont, IBM, Herman B. Bouma, Buchanan Ingersoll & Rooney PC, Carol A. Dunahoo, Baker & McKenzie LLP, Hans F.W. Flick , KPMG LLP, Robert H. Green, Skadden, Arps, Slate, Meagher & Flom LLP, Jeffrey A. Levenstam, Ernst & Young LLP, Sarita Mohapatra, PricewaterhouseCoopers LLP, William J. Sample , Microsoft, and Program Manager Roger D. Wheeler, KPMG LLP. The Program Committee from India included: R Bhupathy, R Bupathy & Co., Mukesh Butani, BMR Advisors, Kuntal Dave, Nanubhai Desai & Co., Nishith Desai, Nishith Desai Associates, Rahul Garg, PricewaterhouseCoopers, Nilesh Kapadia, M/s Nilesh M Kapadia & Co, Ragunathan Kannan, Sathguru Management Consultants, Jitendra Sanghvi, Jitendra Sanghavi & Co.

Click here to access the website for the handouts from this meeting.

IFA USA members have been provided with a complimentary issue of the Taxmann Special issue on the Joint Meeting of the India and USA Branches of IFA. The copy was sent to all members by email on July 31 2009. If you did not receive this email please contact the office and we will resend the .pdf to you or click here to download. It has also been added to the website in the research database.

Thank you to the Sponsors of the Joint Meeting: KPMG, PricewaterhouseCoopers, Ernst & Young, Alvarez & Marsal, DLA Piper, Fenwick & West, Kilpatrick Stockton, Taxmann, and IBFD.