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IFA USA International Tax Conference: "The Tax Cuts and Jobs Act – A Three-Year Review"
December 16 – 18, 2020
Featuring prominent speakers from IRS and Treasury
Register Now!
As you may know, the George Washington University Annual Institute on Current Issues in International Taxation will not be held this December. IFA USA undertaken to work with the IRS and Treasury to present an alternative virtual event with many of the same speakers to provide participants with important updates in international tax.
The IFA USA International Tax Conference: "The Tax Cuts and Jobs Act – A Three-Year Review" will be held December 16, 17, and 18, with substantive sessions for a few hours each day on international tax topics, featuring prominent speakers from private practice and government. We have invited speakers from the IRS and Treasury and have developed what is sure to be a unique, interesting and informative program over the three days.
The panel sessions will include:
- The Role of Foreign Branches Post-TCJA
- International Tax Controversy Panel (LB&I)
- Repatriation: How to Repatriate Earnings (and Cash) Post-TCJA
- Privileges and Penalties – Maximizing Your Protections and Minimizing Your Regrets (Ethics CLE)
- Current Developments OECD
- Fireside Chat with Assistant Secretary David Kautter (invited)
The program is designed to provide a forum and encourage an exchange of views between government and private sector panelists, and is designed for:
- Corporate tax executives responsible for international tax matters
- Law firm partners and associates working in the international tax area
- Accounting firm partners and managers working in the international tax area
- Members of the academic community interested in the latest technical developments in international taxation
- Government and other professionals working in international tax
Learning Objectives – At the conclusion of this program, participants will be able to:
- Better understand technical aspects of recent changes in US tax rules in various specialty areas. Examples are BEAT, the FTC and GILTI.
- Discuss what is coming from the OECD, other institutions, and tax authorities in other countries. Examples are BEPS, Pillars 1 and 2, BREXIT, implementation of the MLI.
- Engage in effective tax planning for client and employers, especially re. dispute resolution, implementation of post-TJCA guidance, and reliance on tax treaties.
Skill level: intermediate to highly advanced
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TECHNICAL PROGRAM
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| Session 1: Wednesday, December 16, 2020 |
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11:00 a.m. – 12:00 p.m. Eastern Time
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Panel: The Role of Foreign Branches Post-TCJA
Sponsored by KPMG and Zedra |
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Chair:
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Brian Jenn, McDermott, Will & Emery
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Panelists:
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Kimberly Blanchard, Weil, Gotshal & Manges
Barbara Felker, Branch Chief, IRS Office of Associate Chief Counsel, International (invited)
Danielle Rolfes, KMPG
Jason Yen, Associate International Tax Counsel, U.S. Department of the Treasury Office of Tax Policy (invited)
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| This panel will provide an overview of the new rules that govern the taxation of foreign branches, with a primary focus on the foreign tax credit rules and the foreign derived intangible income (FDII) rules. Panelists will discuss key issues, including the definition of a foreign branch, determining income attributable to a foreign branch, and the tax consequences of earning income in a foreign branch. The panel will consider the relevant Code provisions, the rules that Treasury and the IRS have provided in regulations to date, and the policy or policies underlying the branch regime. |
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12:00 p.m. – 1:00 p.m. Eastern Time
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Panel: International Tax Controversy
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Chair:
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Josh Odintz, Baker McKenzie
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Panelists:
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Jennifer Best, Assistant Deputy Commissioner, International, Internal Revenue Service
John Hinding, Director, Cross Border Activities Practice Area, Internal Revenue Service
Kat Saunders Gregor, Ropes & Gray
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| This panel will address recent LB&I's transfer pricing and TCJA audit initiatives. We will also discuss current tax controversy developments, including possible challenges to the validity of TCJA regulations. |
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| Session 2: Thursday, December 17, 2020 |
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11:00 a.m. – 12:30 p.m. Eastern Time
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Panel: Repatriation: How to Repatriate Earnings (and Cash) Post-TCJA
Sponsored by Covington |
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Chair:
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Michael Caballero, Covington
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Panelists:
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Jose Murillo, EY
Gretchen Sierra, Deloitte
Laura Williams, Branch Chief, IRS Office of Associate Chief Counsel, International (invited)
Brenda Zent, Special Advisor on International Taxation, U.S. Department of the Treasury (invited)
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| The TCJA's promise of ending the "lock-out" effect for deferred foreign earnings has been less than fully realized and the repatriation of these earnings (and cash) remains a challenge even though distributions from controlled foreign corporations (CFCs) are generally exempt from U.S. taxation. This panel will provide an overview of the issues confronting U.S.-based multinationals when bringing home their foreign earnings, including a discussion of the new previously taxed earnings and profits (PTEP) regulations (we hope, assuming they have been released), other relevant guidance, and practical approaches to successfully navigate the complicated rules that has been developed to implement the changes made by the TCJA. |
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12:45 p.m. – 1:15 p.m. Eastern Time
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Fireside Chat with Assistant Secretary David Kautter (invited)
Interviewer: L.G. "Chip" Harter, Deputy Assistant Secretary (International Tax Affairs), U.S. Department of the Treasury
Sponsored by Grant Thornton |
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| Session 3: Friday, December 18, 2020 |
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11:00 a.m. – 12:00 p.m. Eastern Time
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Panel: Privileges and Penalties – Maximizing Your Protections and Minimizing Your Regrets (Ethics) |
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Chair:
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Diana Wollman, Cleary, Gottlieb
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Panelists:
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Caroline Ciraolo, Kostelanetz & Fink
Erin Gladney, Baker McKenzie
Amanda Leon, Caplin & Drysdale
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| This panel will address hot issues and current developments in privileges and penalties. Using the ongoing Sanmina controversy as a springboard the panel will illustrate through realistic fact patterns what we know and don’t know about when various privileges attach in the first instance, how taxpayers can share privileged communications with those who need to know (preparers, valuation experts, accountants, counterparties, the IRS), how to avoid having a selective disclosure become a subject matter waiver, and how to avoid other pitfalls and bad consequences. |
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12:15 p.m. – 1:15 p.m. Eastern Time
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Panel: Current Developments OECD
Sponsored by KPMG and PwC |
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Chair:
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Michael Plowgian, KPMG
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Panelists:
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Patrick Brown, PwC
Rocco Femia, Miller & Chevalier
Vincent van der Lans, Loyens & Loeff
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| This panel will provide an overview of recent international tax developments, including recent guidance from Treasury and the IRS, as well as the OECD Pillar 1 and Pillar 2 blueprints. |
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Register Now!
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Sponsors are Welcome!
For sponsorship and exhibiting opportunities, please contact Michael Davis:
E. michaeld@ifausa.org T. 1-604-341-9453.
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