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IFA USA New York Region Fall Seminar
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When: Monday, December 7, 2015
8:30 AM - 1:00 PM
Where: EY Conference Center
5 Times Square
New York, New York  10036
United States
Contact: IFA USA

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

Monday, December 7, 2015
Program: 8:30 am - 1:00 pm

Event Location:
EY Conference Center

5 Times Square

New York, NY


Panels will be broadcast as individual webinars. To register, please select NYWeb0 Webinar Only as your registration type and choose any combination of the four sessions that you would like to view. Webinar login details will be provided via email on Friday, December 4, 2015. 


Welcome and Introduction

Peter Connors, Vice President of the New York Region, Partner, Orrick Herrington & Sutcliffe LLP


Section 871(m) Regulations

We will discuss how the 871(m) regulations apply to various product classes (swaps, notes, listed options) and interpretative issues raised by the regulations.

Andrew Chalnick, JP Morgan
  Panelists: Jeffrey D. Hochberg, Partner, Sullivan & Cromwell LLP
Richard Maile, Executive Director, JP Morgan Chase
Jonas Robison, Associate, Orrick, Herrrington & Sutcliffe LLP

Outbound Transfers to Partnerships after Notice 2015-54

The panel will explore the implications of Notice 2015-54, which applies Section 721(c) to outbound transfers to partnerships including related foreign partners

Richard L. Reinhold, Willkie Farr & Gallagher LLP
  Panelists: Marjorie Rollinson, Deputy Assistant Chief Counsel International (Technical), Internal Revenue Service
Joseph Calianno, BDO, Partner and International Technical Tax Practice Leader

BEPS: Practical Implementation Issues

Practical responses to the BEPS initiative in financing, supply chain, country by country reporting, and intellectual property.  The session will review the most relevant OECD guidance around hybrid financing, permanent establishment, and intellectual property transfer pricing, and discuss the approach well advised organization are taking today in response to local country adoption of these new OECD guidelines.

Todd Izzo, Deloitte Tax LLP
   Panelists: Jonny Lindroos, Partner, Northeast Region International Tax Services Group Leader, EY LLP
Mathew Ryan, UK International Tax Partner, PwC LLP

Outbound Asset Transfers after the New Section 367 Regulations

This panel will address outbound transfers of assets, focusing on IP, and will include a discussion with the IRS on the recent regulatory guidance on longstanding issues.

Colleen O'Neill, Partner, EY LLP
  Panelists: Marjorie Rollinson, Deputy Assistant Chief Counsel International (Technical), Internal Revenue Service
Eric Sensenbrenner, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
Stephen Blough, Principal, KPMG LLP
IRS Update
Marjorie Rollinson, Deputy Assistant Chief Counsel International (Technical), Internal Revenue Service

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
Nov 30
Dec 1
On or Before
Nov 30
Dec 1
First Registration $125 $150 $200 $225
Additional Registrations:2
Second Registration $100 $125 $175 $200
Third & Subsequent Registration $75 $100 $150 $175

 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 NY2015DEC 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 December 1, 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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