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2020 IFA USA ANNUAL CONFERENCE AGENDA
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| Thursday February 27 |
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7:00 a.m.
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Registration Opens |
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7:00 – 8:00 a.m.
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IFA USA Branch EC, RVP and Council Breakfast |
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8:00 – 8:30 a.m.
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Welcome Remarks |
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Sol Coffino, President, IFA USA Branch
Murray Clayson, President, Central IFA
Ken Vacovec, Chair, 2020 Annual Conference
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8:30 – 9:30 a.m.
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Plenary Session – Technology Panel |
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Chair:
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Brigitte Muehlmann, Babson College
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Panelists:
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Alex ("Sandy") Pentland, MIT Professor, Media Lab Co-founder
Jeffrey Saviano, EY Global Tax Innovation Leader, MIT Connection Science Fellow, Co-lead of MIT/EY
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| The objective of the technology session is to offer a peek “under the hood” in connection with the technology issues that affect the taxation of the digital economy and current tax system improvement efforts. The session will start with a
brief primer on the mechanics of the digital economy, followed by dynamics that complicate digital taxation, such as economics of two-sided markets, as well as the increasingly blurred lines between products, services and software. It
will then turn to how advanced technology tools can be employed to classify transactions, assets, people, etc. to detect tax data inaccuracies, and to predict tax outcomes. |
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9:30 – 10:30 a.m.
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Plenary Session – Unilateral Approaches to Taxation of the Digital Economy – Threshold Nexus, Cloud Classification, and Digital Service Taxes ("DST's") |
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Chair:
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Matt Schnall, WilmerHale
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Panelists:
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Peter Blessing, Associate Chief Counsel International, Office of Chief Counsel
Olivier Dauchez, Gide Loyrette Nouel
Carol Tello, Eversheds Sutherland
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| This panel will discuss three issues facing individual tax jurisdictions in adapting tax rules to the digital economy – nexus, classification, and apportionment. The panel will focus specifically on the use of threshold nexus rules in U.S.,
state taxation, the classification of cloud solutions under Proposed Treas. Reg. §1.861-19, and the recently enacted French Digital Services Tax. |
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10:30 – 11:00 a.m.
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Refreshment Break
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11:00 a.m. – 12:15 p.m.
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Plenary Session – OECD Proposals for Taxing the Digital Economy |
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Chair:
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Stephen Shay, Harvard University
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Panelists:
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Gary Sprague, Baker & McKenzie
Robert Stack, Deloitte
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YIN Reporter:
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Christopher Beck, Vacovec, Mayotte & Singer
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| This panel will review the OECD/Inclusive Framework’s efforts to address international taxation of the digital economy, including OECD Secretariat’s “Unified Framework” proposal to shift allocation of taxing rights to market countries and
“GloBE” minimum tax proposal. The panel will seek to illuminate interests of the various stakeholders (the United States, other countries and multinational businesses) and evaluate the state of the project in terms of tax policy, domestic
and global politics and business practicality. |
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12:15 – 1:45 p.m.
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Lunch with Keynote Speaker: IRS Commissioner, Charles P. Rettig
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1:45 – 2:45 p.m.
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Breakout Session 1A – Transfer Pricing Panel
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Chair:
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Jill Weise, Duff & Phelps
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Panelists:
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Jennifer Best, LB&I Director, Treaty and Transfer Pricing Operations Practice Area, Internal Revenue Service
Sean Foley, KPMG
Sam Maruca, Covington & Burling
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YIN Reporter:
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Zachary Held, Duff & Phelps
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| The panel will discuss recent developments in transfer pricing and how these developments impact transfer pricing in practice. Topics will include: ICAP 2.0, Ways to improve 6662 documentation; Impact of TCJA, Altera – amended returns or catch
up payments for stock based compensation, Spontaneous exchange – APA, Impact and experience since the January 2018 directives, and BEPS Update – Pillar I and Pillar 2. |
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Breakout Session 1B – The FTC in a Post-TCJA World
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Chair:
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Douglas Stransky, Sullivan & Worcester
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Panelists:
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Barbara Felker, Internal Revenue Service, Chief Branch 3
Dirk Suringa, Covington & Burling
Treavor Weeden, PwC
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| The TCJA repealed the deemed-paid credit under Code Section 902, modified the deemed-paid credit rules under Section 960 and added separate foreign tax credit limitation categories for foreign branch income and Global Intangible Low-Tax Income
(GILTI). In addition, the TCJA changed the calculation of taxable income for purposes of the Foreign Tax Credit limitation by disregarding certain expenses and repealing the use of fair market value method for allocating interest expense.
This session will examine the new post-TCJA foreign tax credit regulations and consider how the rules work in light of the various regulations and consider how the new rules work in light of the various types of foreign income categories
and credit limitations in a post-TCJA world. |
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1:45 – 5:00 p.m.
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Special Breakout Session 1C – MIT Media Lab Visit
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Alex ("Sandy") Pentland, MIT Professor, Media Lab Co-founder
Jeffrey Saviano, EY Global Tax Innovation Leader, MIT Connection Science Fellow, Co-lead of MIT/EY
Sandy Pentland, MIT, and Jeffrey Saviano, EY, inviting up to 50 conference participants to a unique full-afternoon breakout session at the MIT Media Lab. The break-out session will address the application of advanced technologies – and
data analysis – to solve complex tax problems within both the private and public sectors, and, how those tax problems significantly impact businesses and tax authorities. Click here to learn more
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2:45 – 3:15 p.m.
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Refreshment Break
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3:15 – 4:15 p.m.
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Breakout Session 2A – International Mergers & Acquisitions Post TCJA |
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Chair:
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Jason Tata, KPMG
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Panelists:
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John Merrick, Internal Revenue Service, Office of Chief Counsel
Larissa Neumann, Fenwick & West
James Tobin, EY
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YIN Reporter:
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Alex Farr, Weil, Gotshal & Manges
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| This panel will discuss the latest developments in cross-border mergers and acquisitions with a focus on the impact of TCJA on transaction structures and post-transaction integration. The discussion will consider the impact of the rules and
recent guidance on GILTI, FDII, BEAT, Section 958(b)(4) attribution, cash repatriation, and 163(j) on typical transaction structures. |
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| Breakout Session 2B – Controversy Panel |
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Chair:
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Thomas Greenaway, KPMG
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Panelists:
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Robert Hanson, EY
Brian Kittle, Mayer Brown
Daniel Nir, Duff & Phelps
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YIN Reporter:
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Michael Berbari, Duff & Phelps
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| This panel will present an overview of current issues and trends in international tax controversy. The panelists will discuss how both taxpayers and the IRS are confronting uncertainties around tax reform implementation, including §965 calculations,
transition-period planning, and other issues. Transfer pricing controversies have multiplied recently. The panel will offer an overview of current cases and trends in U.S. transfer pricing disputes, both administrative and in litigation. |
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4:15 – 5:15 p.m.
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Breakout Session 3A – BEAT & GILTI Guidance: A Leap Forward? |
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Chair:
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Colleen O’Neill, EY
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Panelists:
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Pedro Corona de la Fuente, Procopio, Cory Hargreaves & Savitch
Rodrigo Fernandez, Economic Partners
Marissa Rensen, Special Counsel, Associate Chief Counsel International
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YIN Reporter:
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Lukas Kutilek, Weil, Gotshal & Manges
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| The panel will cover the burning question on everyone’s mind: will taxpayers need the extra day in leap year to contend with the new guidance? The discussion will address the 2019 regulations related to BEAT and GILTI, including elections
and planning available to potentially mitigate the impact of both. |
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| Breakout Session 3B – Partnerships, Subchapter S and High Net Worth Individuals Post-TCJA |
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Chair:
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Arthur Kerr, Vacovec, Mayotte & Singer
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Panelists:
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Scott Harty, Alston & Bird
Barbara Rasch, KPMG
Dina Weisen, Deloitte
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| This panel will discuss the impact of TCJA on partnerships, Subchapter S and high net worth individuals including 962 elections, and the repeal of 958(b)(4), and Smith v. Commissioner. |
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Evening:
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5:15 – 6:00: YIN Reception
Sponsored by Loyens & Loeff
6:00 – 6:45: WIN Reception
Sponsored by EY
6:15 – 11:00: Gala Evening at the Fairmont Copley Plaza Hotel
6:15 – 7:15: Cocktail Reception
7:15 – 11:00: Dinner
Sponsored by
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| Friday February 28 |
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7:00 – 8:00 a.m.
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Breakfast Session – Commercial Reasonableness, Transactional Evidence, and the Arm’s Length Standard: Recent Developments and Experience
Sponsored by Economics Partners - A Ryan Company
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Speakers:
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Bryan Daughtery, Economics Partners - A Ryan Company
David Suhler, Economics Partners - A Ryan Company
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An increasingly common question to arise in transfer pricing cases is whether third parties do actually enter into similar transactions in the open market. We review these developments in light of the history of the arm’s length standard
and recent guidance from tax authorities and the OECD, and examine implications for the use of transactional data in designing and documenting intercompany transactions.
Click here to RSVP for this breakfast
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8:00 – 8:15 a.m.
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Welcome Remarks |
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Ken Vacovec, Chair, 2020 Conference
Josh Richardson, Chair, 2021 Conference
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8:15 – 9:30 a.m.
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Plenary Session – Post Brexit European Tax Planning |
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Chair:
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Vincent Van Der Lans, Loyens & Loeff
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Panelists:
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Serge Huysmans, EY
Daniel Lehmann, Baer & Karrer
Peter Maher, A&L Goodbody
Kathleen Russ, Travers Smith
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YIN Reporter:
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Marlous Verhoog, Loyens & Loeff
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| Discussion regarding alternative European headquarter jurisdictions as U.S. multi-nationals face Brexit. |
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9:30 – 10:30 a.m.
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Breakout Session 4A – Corporate Tax Executives
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Chair:
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Mark Organisak, Vertex
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Panelists:
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Mark Colabella, Dell Technologies
David Paul, American Honda Motors
Tom Roesser, Microsoft
Randi Rosenberg, Siemens
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| Issues confronting and concerning U.S. tax executives in light of TJCA and OECD actions, etc. |
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Breakout Session 4B – Taxation of Cryptocurrencies
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Chair:
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Franziska Hertel, Ropes & Gray
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Panelists:
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Julie Hogan Rodgers, WilmerHale
Suzanne Sinno, Attorney at IRS Office of Chief Counsel
Julia Ushakova-Stein, Fenwick & West
Christopher Wrobel, Special Counsel to the Associate Chief Counsel
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| This panel will address current tax developments for cryptocurrencies, including valuation and domestic and international tax considerations. |
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10:30 – 11:00 a.m.
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Refreshment Break
Sponsored by Economics Partners - A Ryan Company
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11:00 a.m. – 12:00 p.m.
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Breakout Session 5A – Life Science Panel |
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Chair:
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David Saltzman, Ropes & Gray
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Panelists:
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Pascal Hinny, Lenz & Staehelin
Mark O’Sullivan, Matheson
Louise Weingrod, Johnson & Johnson Vice President Global Taxation
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YIN Reporter:
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Chris Shim, Ropes & Gray
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| The panel will explore the evolving U.S. and global tax policy ecosystem impacting innovation in the life science industry. Topics include R&D allocation and capitalization rules, Pillar 1, Pillar 2 and super-deductions/innovation boxes. |
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| Breakout Session 5B – Taxpayer Advocate & International Taxpayer Rights |
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Chair:
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Joshua Odintz, Baker McKenzie
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Panelists:
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Jeramiah Coder, PwC
Nina Olson, Executive Director, Center for Taxpayer Rights
Stephen Shay, Harvard University
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| This panel will discuss the management of data by governments and taxpayers in a global tax system. In the case of global, coordinated audits, how do taxpayers and tax authorities address the sharing of tax return information? How do governments
share information outside of coordinated audits? Should taxpayers be concerned by the management of their bank account information under the Foreign Account Tax Compliance Act (“FACTA”) and the Common Reporting Standard? How are taxpayers
addressing the transmission of massive amounts of data to governments? Do privacy protections matter? |
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12:00 – 1:30 p.m.
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Lunch
- IFA USA Branch Writing Prize Award Presentation
- IFA USA Branch Annual Members' Business Meeting
- IFA USA Incoming President, Carol Tello
- Keynote Speaker: Michael Keen, Deputy Director of the International Monetary Fund Fiscal Affairs Department who will speak on "How the TCJA is affecting other country tax systems"
Lunch sponsored by Orrick
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1:30 – 2:30 p.m.
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Breakout Session 6A – Treaty & Multilateral Instrument Update
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Chair:
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Brainard ("Skip") Patton, Boston University School of Law
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Panelists:
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Mary Bennett, Baker & McKenzie
Harrison Cohen, Deloitte
Cathy Schultz, National Foreign Trade Council
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Treaty update, focusing on recent protocols, OECD Pillar One and Pillar Two proposals, MLI developments including a possible true multilateral treaty, and BEAT & GILTI implications.
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Breakout Session 6B – Regulatory Update
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Chair:
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Lewis Greenwald, DLA Piper
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Panelists:
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Kevin M. Jacobs, Alvarez & Marsal Taxand, LLC
Shi-Chieh ("Suchi") Lee, PwC
Danielle Rolfes, KPMG
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YIN Reporter:
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Francesca Witcher, PwC
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An unprecedented volume of regulatory guidance was issued in 2019 (GILTI, FDII, BEAT), and more is anticipated in 2020. This panel will survey the year that was and discuss the 2019/2020 regulatory guidance not covered by other panels
– the anti-hybrid guidance and the regulations under sections 163(j), 245A, 385, 901(m) and 987.
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2:30 – 3:00 p.m.
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Refreshment Break
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3:00 – 4:00 p.m.
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Plenary Session – After the Golden Age of U.S. International Tax Planning, What’s Next?
Sponsored by Fenwick & West
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Chair:
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Ameek Ponda, Sullivan & Worcester
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Panelists:
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Ron Dabrowski, KPMG
William Skinner, Fenwick & West
Moshe Spinowitz, Skadden, Arps, Slate, Meagher & Flom
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YIN Reporter:
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Rita Ryan, Vacovec, Mayotte & Singer
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| Some would describe the last two or three decades as the Golden Age of US International Tax Planning on account of mega-trends such as inversions, repatriations, and intellectual property migrations. But the TJCA and OECD efforts have changed
the terrain dramatically. What remains, if anything, of these older mega-trends, and what will be the mega-trends of the brave, new world that we now inhabit? This panel will cover the mega-trends of international tax planning’s past,
present and future tax planning in a post TCJA and OECD environment. |
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4:00 – 5:00 p.m.
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Plenary Session – Latest Transfer Pricing Operational Approach – UK Tax Authority Perspective
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Chair:
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Philip Martinos, PwC
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Panelists:
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Kevin Brown, PwC
Mark Carnduff, HMRC
Chris Palmer, HMRC
Richard Steele, HMRC
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Senior officials from the UK Tax Authority, HM Revenue & Customs (“HMRC”), will present on the latest operational approach to Transfer Pricing. In particular, HMRC will talk through the background to this latest approach to Transfer
Pricing, why now and how the Diverted Profits Tax and the Profit Diversion Compliance Facility, a new co-operative compliance initiative, fits into this. There will then be a panel discussion led by Philip Martinos, PwC UK, with the
opportunity for questions from the audience.
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Additional sponsors include:
Lanyards sponsored by KPMG
WiFi sponsored by Covington
App sponsored by Duff & Phelps
WIN Salon sponsored by Grant Thornton
Delegate Pens sponsored by Wolters Kluwer
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