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New England Regional IFA Fall Conference
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Cambridge MA - November 14 - New England Regional IFA Fall Conference

11/14/2019
When: Thursday, November 14, 2019
8:30 - 11:45 AM
Where: Harvard Law School, Austin Hall-Room 111
Cambridge, Massachusetts  02138
United States
Contact: IFA USA
1-866-298-9464


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New England Regional IFA Fall Conference
Thursday, November 14, 2019
8:30 AM - 11:45 AM

Location:
Harvard Law School
Austin Hall-Room 111
Cambridge, Massachusetts 02138

Free to In-Person Attendees—But Please Consider Joining IFA! Please see event registration and IFA membership links below.

Program:

7:45AM-8:30AM

Registration and Continental Breakfast

8:30AM-8:45AM

Welcome and Opening Remarks
David Saltzman, Regional Vice President, New England Region IFA USA

8:45AM-10:00AM

Do We Have a CFC?  Considerations for U.S. Corporations and Investment Funds.  
This panel will survey the impact of the TCJA and recent administrative guidance on the application of “downward attribution” rules in determining (i) whether a foreign corporation is a CFC and (ii) whether various tax rules should apply to a CFC.  The panel also will review proposed regulations that would determine U.S. shareholder status at the level of a partner (rather than for example, an investment partnership) which can limit the circumstances when partners in a domestic investment fund are required to include subpart F and GILTI.

Panelists:

Mark Colabella Vice President, Enterprise Tax Planning, Dell

Stephen Massed, Managing Director, KPMG, Boston

Neelu Mehrotra, Managing Director, EY National Tax

Elaine Murphy, Ropes & Gray, LLP, Boston, MA

10:00AM-10:30AM

Break

10:30AM-11:45AM

Tax Treaties and the OECD Digital Taxation Framework

This panel will discuss recent OECD proposals to reform the approach to the taxation of cross-border digital commerce and other remote seller arrangements.   Particular emphasis will be on the impact of proposals to expand source and market-based taxation in current and future treaties. 

Panelists:

Mary Bennett, Baker & McKenzie, Washington DC 
H. David Rosenbloom, Caplan & Drysdale, Washington DC
Stephen Shay, Senior Lecturer, Harvard Law School, Cambridge, MA

Registration:

To register please visit: 

This event is open to IFA USA members and non-members. Click here to become a member today.

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