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IFA USA New York Region International Tax Seminar
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When: July 21st, 2015
345 Park Ave.
New York, New York  10154
United States

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Online registration for this event is now closed.  Please visit the registration desk if you wish to register on-site.


Tuesday, July 21st, 2015
Program: 8:30 am - 12:30 pm

Event Location:
345 Park Ave.
New York, NY 10154


International Hot Topics
These topics will include: (1) recent IRS guidance on Notice 88-108 impacting section 956; (2) the final section 909 regulations; (3) Rev. Rul. 2015-10 relating to drop and check transactions; and (4)recent IRS guidance relating to the branch rate disparity test.

Karen Holden, Principal, EY LLP
Louise Weingrod, Vice President, Global Taxation, Johnson & Johnson
Chase Wink, Associate, Skadden, Arps, Slate, Meagher & Flom LLP
Brian Jenn, Attorney Advisor, U.S. Treasury
9:45am-10:00am Break
10:00am-11:00am The U.S. Model Treaty
On May 20, 2015, Treasury proposed five sweeping changes to the 2006 Model US tax treaty. The 5 changes are novel and include limitations applicable to recipients of payments from related parties eligible for “special tax regime” benefits, expansion of the exempt triangular PE rule found in many LOB provisions to a broader more general application, a subsequent change in law provision that permits a State to disown only the withholding portions of the treaty, an expatriated entity set of restrictions that in some sense is broader than the inversion provisions and a significant overhaul of the LOB article that includes adding a derivative benefits paragraph distinct from existing treaties and changes to the active trade or business, qualified person and competent authority tests. Many of the changes reflect Treasury’s response to BEPS as reflected in BEPS Action 6. This panel will discuss these provisions.
Manal Corwin, Principal, KPMG LLP
Mark Stone, Partner, Holland & Knight LLP
Peter Glicklich, Partner, Davies Ward Phillips & Vineberg LLP
11:00am-12:15pm Foreign Desk Update; Implementing BEPS and Other Developments
Always popular with members, this panel will explore "nuts and bolts" (and how to keep the wheels on) as BEPS moves towards implementation.

John Harrell, Global Tax Director, GE Treasury
Gerrit Groen, Director, Global Tax Desks, EY LLP
Pierre Revault, Principal, Deloitte LLP
Sebastien Maury, Senior Manager, International Corporate Tax, KPMG LLP
Jonathan Cooklin, Partner, Davis Polk & Wardwell London LLP
12:15pm-12:30pm Treasury Update
Brian Jenn, Attorney Advisor, U.S. Treasury


This event is open to IFA USA Members and non-Members.
Register more than one person from one organization and receive a discount on the additional registrations!

Full time Government Employees and Professors receive a 50% discount on registration. See superscript 3 below for instructions on how to claim this discount.

Registration Type IFA Member Non-Member
Federal Tax ID 23-7068849 On or Before
July 10
July 11
On or Before
July 10
July 11
First Registration $100 $125 $200 $225
Additional Registrations:2
   Second Registration $75 $100 $150 $175
   Third & Subsequent Registration $50 $75 $125 $150



1If you would like to join IFA and receive the discounted member rate, click here and join before registering for the seminar:
2Each additional attendee must complete a separate registration form and check the appropriate box for their specific registration fee category.
3Government/Academic Discount applies only to full-time government employees and full -time professors.  Enter promo code NY2015JUL upon checkout.

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 $30 processing fee and must be received in writing at the above address on or before July 7, 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).


  • 2604 Elmwood Avenue, #347, Rochester, NY 14618
  • Telephone: 866-298-9464
  • Fax: 866-303-0626
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