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IFA USA New York Region International Tax Seminar
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Where: PwC LLP
300 Madison Ave.
New York, New York  10017
United States
Contact: Larissa Johnston

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Wednesday, July 20, 2016


New! Sessions will be offered by  webinar



8:25 – 8:30 AM

Chairman's Introduction

Peter Connors, RVP IFA USA New York Region


8:30 – 10:00 AM

 Webinar Session 1

The Section 385 Regulations and Their Impact on the Financial Services Sector

The section 385 regulations, if finalized as proposed, will have an especially significant impact on regulated financial institutions. This session will explore and the appropriateness of applying the regulations to that industry and the modifications that have been suggested to those regulations, especially for financial services entities and related areas. In particular, the session will examine the recommendations of the bar association and other reports that are expected to have been issued shortly before the conference.



Allen Friedman, JP Morgan



Paul Crispino, Deloitte Tax LLP

Lucy Farr, Davis Polk & Wardwell

Daniel McCall, Deputy Associate Chief Counsel (International-Technical), IRS

James Peaslee, Cleary Gottlieb Steen & Hamilton





10:00 – 10:15 AM







10:15 – 11:15 AM

Webinar Session 2 

The New Model Treaty

In February 2016 the Treasury Department released the first new version of the U.S. model income tax treaty in a decade, reflecting both technical changes and policy initiatives designed to modernize, and in some cases toughen, Treasury’s position on the proper balance between eliminating double taxation and limiting opportunities for non- or reduced taxation through perceived abuses. The influence of the OECD’s ongoing base erosion and profit shifting (BEPS) initiative, as well as U.S. reactions to that program, are evident in many of the new model's provisions.

This panel is expected to set the new model in the context of ongoing international tax developments and analyze some of its more important innovations of interest to multinational companies, including those calling for the denial of treaty benefits following certain changes in law, attributable to offshore permanent establishments (the "triangular case") or income benefiting from special tax regimes, as well as a revised limitation on benefits (LOB) article.

The panel will also discuss the foreign countries' reaction to the Model Treaty and briefly discuss the EU Action Plan.



Richard Andersen, WilmerHale




Steve Nauheim, PwC LLP

Aroen Rambhadjan, Netherlands Desk, KPMG LLP

Vanessa Tollis, Kilpatrick Townsend & Stockton LLP










11: 15 – 12:15 PM

Webinar Session 3 

Hybrid Mismatches Around the World

Action 2 of the OECD BEPS proposal includes a comprehensive hybrid match proposal. This will panel will review the OECD hybrid mismatch proposals, country actions to date in implementing them, EU proposals and practical issues facing multinational companies.



Jim Tobin, EY LLP




Jose Bustos, EU Desk, EY LLP

Neill Fuller, Australia Desk, PwC LLP

James Taylor, EY UK Desk Partner NY






12:15 – 12:30 PM

Webinar Session 3 Ctd. 

IRS Update



Daniel McCall, Deputy Associate Chief Counsel (International-Technical), IRS




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 12
July 13
On or Before
July  12
July 13
First Registration $100 $125 $200 $225
Additional Registrations:2
Second Registration $75 $100 $150 $175
Third & Subsequent Registration $50 $75 $125 $150

Webinar Session  $25 $25  $35 $35 

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 NY2016JUL 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 12, 2016; no refunds will be given with respect to requests received after that date. 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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