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IFA USA Atlanta Region Seminar
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When: Wednesday, May 27, 2015
From 8:30 AM until 2:00 PM
Where: Buckhead Ballroom
Grand Hyatt Atlanta
3300 Peachtree Rd., NE
Atlanta, Georgia  30305
United States
Contact: IFA USA

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Wednesday, May 27, 2015
Program: 8:30 am - 2:00 pm


Annual International Tax Seminar
Featuring Speakers from the Industry and Professional Service Firms                  



Event Location:
Grand Hyatt Atlanta in Buckhead
3300 Peachtree Rd NE
Atlanta, Georgia 30305



Panel 1: M&A Structures, Including Inversions.

This panel will review recent trends in structuring and implementing mergers and acquisitions and related international tax planning. This will include a discussion of the desirability of a section 338 election in light of section 901(m) and an update on inversions.



Sam Kaywood, Alston & Bird LLP, Atlanta

Will Dixon, Citigroup Global Markets Inc., New York

Marty Collins, PricewaterhouseCoopers LLP, Washington DC

Panel 2: Subpart F, Section 956 and Other Repatriation Issues.

This panel will review various repatriation trends and structuring techniques and the related IRS responses, including the aggressive use of the section 956 anti-abuse rule. The panel will also discuss related accounting and provisioning implications under APB 23.



Todd Behrend, Ryan LLC, Atlanta

Ron Dabrowski, KPMG LLP, Washington (former Special Counsel, U.S. Treasury Office of Tax Policy)

Marc Schwartz, Schwartz International, Atlanta

Anne Maher, The Coca Cola Company, Atlanta

Panel 3: Current Developments.

This panel will cover current developments, including new trends in tax treaties, international tax cases, IRS rulings, etc. The panel will also provide an update on European matters, including EU state aid cases and OECD BEPS initiatives.



Scott Harty, Smith Gambrell & Russell LLP, Atlanta

Vincent Mahler, Arendt & Medernach, New York

Sam Tae, Ryan LLC, Atlanta

Luncheon Speaker: Status of Tax Legislation and International Tax Reform


Sean Hailey, Ernst & Young LLP, Washington DC (former Tax Advisor to House Ways & Means Committee), Ryan LLC, Atlanta


This event is open to IFA USA Members and non-Members.

Full time Government Employees and Professors receive a 50% discount on registration.



IFA USA Member


Non Member


Financial Hardship Policy

Scholarships are available in the event of financial hardship. An individual wishing to obtain a scholarship should apply in writing at least 2 weeks in advance of the program date, explaining the circumstances of such person's financial hardship. The amount of the scholarship generally depends on salary as follows:

Unemployed – Full Scholarship; Income up to $15,000 – 75% discount;
Income $15,000–$30,000 – 50% discount; Income above $30,000 – no discoun

Cancellation Policy:
Speakers, content and panel order are subject to change without notice, and registrations may be limited due to space or other constraints.

This seminar is subject to cancellation due to insufficient registration or other reasons, in which case refunds will be made free of processing fees. All other refund requests are subject to a $50 processing fee and must be received in writing at the above address on or before May 13, 2015; no refunds will be given with respect to requests received after that date. All refunds are limited to the amount of registration fees previously paid less applicable processing fees. Substitutions are welcome at any time (including by walk-in registration).


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