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IFA USA Atlanta Region Spring Seminar
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When: Wednesday, June 15, 2016
8:30am - 2:00pm
Where: Intercontinental Buckhead
3315 Peachtree Rd.
Atlanta, Georgia  30326
United States
Contact: IFA USA

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Wednesday, June 15, 2016
Program: 8:30 am - 2:00 pm

Annual International Tax Seminar

Event Location:

Intercontinental Buckhead
3315 Peachtree Rd NE
Atlanta, GA 30326



Continental Breakfast

Introduction:Sam Kaywood, Alston & Bird LLP, Atlanta

Panel 1: BEPS/ EU Update.
This panel will review recent issues arising under the OECD base erosion profit shifting initiative. This will include recent developments such as the January 28, 2016 EU Proposed anti-tax avoidance directive as well as a discussion of the continued viability of hybrid debt (PECS, CPEC, etc.), finance branch and double-Irish structures.

Todd Behrend, Ryan LLC, Atlanta

Scott Harty, Alston & Bird LLP, Atlanta

Jurjan Wouda Kuipers, Luxembourg Tax Desk, Ernst & Young LLP, New York


9:45am–11:00am Panel 2: Implications of Proposed Section 385 Regulations.
This panel will review the proposed section 385 debt vs. equity regulations, including what constitutes an expanded group, the documentation requirements and the leveraged funding rules. The panel will explore the impact on both inbound and outbound uses of debt, the implications for cross-chain 304 transactions as well as repatriation planning.

David Warren, PricewaterhouseCoopers LLP, Atlanta

Ron Dabrowski – KPMG LLP, Washington, DC
Lewis King, Ernst & Young, LLP, New York
Keith Sieverding, Deloitte LLP, Washington, DC
Katie O’Grady, Equifax Inc, Atlanta

11:00am–12:30pm Panel 3: Current Developments.
This panel will cover current developments, including the new U.S. Model Tax Treaty, the new 956 Regulations and other developments affecting repatriation issues, new rules for outbound transfers of goodwill under Section 367 as well as the use of partnerships in outbound transfers.

Rob Wilkerson, KPMG LLP National Office, Atlanta

Marty Collins, PricewaterhouseCoopers LLP, Washington, DC

Monica Loving, BDO, Atlanta
Mike Thompson, Deloitte LLP, Atlanta

Robert Beard, King & Spalding LLP, Atlanta

12:30pm–2:00pm Luncheon Speaker
Raymond Stahl, [ACI]



Registration Fees:

IFA USA  Member $195
 Non Member $225 

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