Agenda:

• 12:00 pm - 12:30 Registration
• 12:30 pm - 1:30 pm - Panel 1
• 1:30 pm - 1:45 pm - Break
• 1:45 pm - 2:45 pm - Panel 2
• 2:45 pm - 3:00 pm - Break
• 3:00 pm - 4:00 pm - Panel 3
• 4:00 pm - 5:00 pm - Cocktails

Panel 1: Structuring for Special Investor Considerations

This panel will discuss fund and co-investment structuring to accommodate the special tax considerations of not-for-profit, sovereign wealth, foreign pension, and other institutional investors.

Moderator:

Kirstin Gallagher, KPMG

Speakers:

John Bennett, Simpson Thacher & Bartlett LLP
Brett Fieldston, Fried Frank
Nina Xue, Brookfield Asset Management

Panel 2: Recent Developments

This panel will discuss recent US international tax developments, including notice regarding FIRPTA considerations relating to inbound F reorganizations, observations on branch profits tax rate applicable to hybrid structures, loan origination and certain other case developments.

Moderator:

Jennifer Lee, Davies

Speakers:

Nita Asher, PwC
Zach Pouga, EY

Panel 3: OB3 and Legislative Process

This panel will discuss the international tax provisions included in the recently passed One Big Beautiful Bill Act and its impact on international tax policy in the United States. The panelists will also provide their observations on the new GILTI (NCTI), FDII (FIDDEI), and BEAT provisions. There will be some discussion of the U.S. position on Pillar 2 and how the new international tax provisions interact with the new U.S. position. 

Moderator:

Rohit Kumar, PwC

Speakers:

Alyson Lawrence, Johnson & Johnson

Kevin Nichols, Uber

Randi Rosenberg, Siemens Corporation
Catherine Schultz, Business Roundtable

Co-hosted by IFA USA and ITI

Registration

IFA USA Members & ITI Members - $100.00
Non-Members  - $150.00

IFA USA Members must sign in to receive member pricing.

If you are an ITI Member, please send an email to info@ifausa.org for discounted registration code.

CPE/CLE

Recommended CLE credits: 3.0 Taxation
Recommended CPE credits: 3.6 Taxes
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. IFA USA National Registry Sponsor # 112000
Program Level CPE: Basic
Program Level CLE: Intermediate
Program prerequisites: None
Advanced Preparation: None
Group Live Event

USA Branch, International Fiscal Association Inc. (IFA USA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org

National Registry Sponsor #112000