Join the Northern California Branch of the International Fiscal Association for a focused discussion on today’s most pressing international tax issues. Current and former leaders from private practice, industry, and government will share insights on:

• Regulatory and legislative developments, including the future of Pillar Two
• Durability of the TCJA model in a post-OBBBA environment
• Customs duty planning and the application of §1059A
• Navigating transfer pricing disputes and competent authority developments

Agenda:

• 2:00 pm - 2:30 pm Panel 1
• 2:30 pm - 3:10 pm Panel 2
• 3:10 pm - 3:50 pm Panel 3
• 3:50 pm - 4:00 pm Break
• 4:00 pm - 4:30 pm Panel 4
• 4:30 pm - 5:00 pm Panel 5
• 5:00 pm - 6:00 pm Holiday-themed Networking Reception

Participants will be able to:

• identify key recent or proposed U.S. and international tax developments (e.g., Pillar Two, §899, CAMT) and explain their potential impact on multinational tax planning over the next 12–24 months.
• evaluate the compliance challenges arising from the §987 and digital content / cloud transaction regulations and apply lessons learned to anticipate potential risks and opportunities.
• analyze the extent to which OBBBA modified or preserved the TCJA framework and gain insights into modelling impacts from a GILTI (NCTI) / FDII (FDDEI) / FTC utilization perspective as well as effective tax rate management.
• to apply §1059A principles to cross-border inventory valuation scenarios and evaluate practical strategies to manage customs duty exposures while maintaining compliance with transfer pricing rules.
• evaluate dispute resolution options for cross-border transfer pricing controversies, including competent authority and APA processes, and apply strategies to mitigate double taxation and enforcement risk in a global context.

Panel 1 – Key Legislative / Regulatory Developments 
As legislative and regulatory activity accelerates in the U.S. and abroad, shifting rules and enforcement priorities are redefining planning roadmaps. We’ll provide a legislative / regulatory update—including enacted and proposed rules and Treasury / IRS projects—then turn to Pillar Two’s move from rollout to enforcement, now shaped by the G7’s June 2025 “side-by-side” statement and its implications for U.S.-parented groups. The panel will also cover potential future legislation such as §899, including how any revival could interact with tax treaties (relief from double taxation, competent authority, and MAP) and practical planning considerations under increasingly assertive foreign tax regimes. On the regulatory front, we’ll touch on CAMT developments, including the latest news on upcoming Notices and proposed regulations.

Speakers:
Steven Kohart – Washington National Tax Principal, PwC 

Panel 2 - Post-Mortem on §987 and Digital Content / Cloud Transaction Regulations: Lessons Learned and Next Steps 
The recent §987 and digital content / cloud transaction regulations have had a significant impact on multinational businesses. With the dust settling, it is time to reflect on the practical challenges, compliance burdens, and strategic opportunities that have emerged. This panel will provide a post-mortem analysis of the §987 and digital content / cloud transaction regulations, focusing on lessons learned from initial compliance efforts, unresolved technical issues and latest developments. The discussion will also touch on the proposed cloud sourcing rules and other ongoing regulatory projects.

Speakers:
Zey Nasser – Managing Director, Andersen Tax LLC 
Gabe Gartner – M&A and International Tax Principal, PwC 
Kodj Gbegnon – International Tax Principal, PwC 

Registration