52nd Annual Conference of the USA Branch of the International Fiscal Association
Thursday, March 21 and Friday, March 22, 2024
New York Athletic Club
180 Central Park S
New York, NY 10019
The event includes two full days, Thursday and Friday, of practical sessions on international tax topics, with eminent speakers joining from private practice, industry, and government. The event will also include two luncheons, a networking cocktail reception, and a banquet.
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YIN Report - International Aspects of Crossborder
PDF (132.01 KB)
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Administration
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4/10/2024
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YIN Report - Recent Foreign Tax Credit Development
PDF (120.56 KB)
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Administration
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4/25/2024
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YIN Report - Ethics
PDF (56.71 KB)
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Administration
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4/10/2024
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YIN Report - Partnership and International Taxatio
PDF (160.63 KB)
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Administration
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4/10/2024
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YIN Report - Update on US International Income Tax
PDF (76.6 KB)
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Administration
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4/10/2024
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YIN Report - Tax Challenges facing Family Offices
PDF (107.97 KB)
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Administration
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5/1/2024
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YIN Report -How the UN is Altering the Internation
PDF (65.39 KB)
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Administration
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4/25/2024
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YIN Report - Penalties in International Tax Practi
PDF (105.35 KB)
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Administration
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4/10/2024
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YIN Report - OECD’s Pillar One
PDF (130.39 KB)
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Administration
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4/10/2024
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YIN Report - Pillar Two
PDF (136.86 KB)
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Administration
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4/10/2024
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More Traps for the Unwary in International Taxatio
PDF (383.47 KB)
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Administration
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3/20/2024
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More Traps for the Unwary in International Taxation
Sponsored by PwC
Moderator: Martin Hunter, PwC
Panelists: Kevin England, DLA Piper
Mark Gasbarra, Forte
Gregory Featherman, Weil, Gotshal & Manges
YIN Reporter: Henry Zeng, PwC
The panel will address traps for the unwary arising in common practice as well highlight potential missed opportunities in planning and compliance. The subject matter draws primarily on US federal income tax issues arising in both inbound and outbound practice including issues encountered in the deal setting.”
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International Aspects of Crossborder Financing
PDF (362.53 KB)
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Administration
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3/18/2024
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Moderator: John Barlow, Baker McKenzie
Panelists: Ege Berber, PwC
Lee Holt, EY
Shane McCarrick, Special Counsel, Office of Associate Chief Counsel (International), IRS (invited)
Michiel Schul, Loyens & Loeff
YIN Reporter: Eric Min, Baker McKenzie
This panel will examine new issues that have recently arisen in intercompany financing, in particular with regard to the interaction of Pillar 2, the DCL rules, and the anti-hybrid provisions in Section 267A. The panel may also discuss the replacement to the funding rule in the final stock buyback regulations and issues that arise from intercompany guarantees.
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Recent Foreign Tax Credit Developments
PDF (427.88 KB)
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Administration
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3/18/2024
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Moderator: Mallory Mendrala, Deloitte
Panelists: Rafic Barrage, Baker McKenzie
JD Hamilton, EY
Britt Haxton, KPMG
Hayley Rassuchine, Office of Associate Chief Counsel (International) IRS (Invited)
YIN Reporter: Varuni Balasubramaniam, Baker McKenzie
This panel will examine recent foreign tax credit guidance in Notice 2023-55 and Notice 2023-80, including the current state of the creditability rules for foreign taxes and the treatment of certain Pillar Two top-up taxes for U.S. federal income tax purposes. This panel will also cover various other issues U.S. taxpayers are facing related to Pillar Two top-up taxes and the foreign tax credit.
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YIN Report - Repatriation
PDF (174.91 KB)
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Administration
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4/15/2024
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Repatriation Planning Panel
PDF (386.14 KB)
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Administration
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3/19/2024
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Moderator: Colleen O'Neill, EY
Panelists: Joseph Calianno, Andersen
Laura Williams, PwC
Brenda Zent, US Department of Treasury (Invited)
YIN Reporter: Raushan Tumabayeva, PwC
This panel will be discussing CAMT Notice on distributions, the 961(c) Notice, and the 367(d) proposed regulations.
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Ethics and Privilege– What’s Trending?
PDF (462.53 KB)
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Administration
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3/19/2024
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Moderator:
Caroline Ciraolo, Kostelanetz
Panelists:
Sharon Katz-Pearlman, Greenberg Traurig
S. Starling Marshall, Crowell Moring
Jeremy Temkin, Morvillo
YIN Reporter: Yelena Niazyan, Kostelanetz
Legal ethics and the availability and impact of legal privilege is an evolving landscape that requires vigilance by tax practitioners in the United States, as we represent clients (individual or corporate) in cross-border transactions, whether across state lines or across the oceans. This panel will discuss some emerging trends and critical issues in the world of legal ethics and privilege, and present real-world scenarios demonstrating how to navigate these challenging and often-turbulent waters.
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Transfer Pricing Developments
PPTX (441.09 KB)
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Administration
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3/18/2024
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Moderator:
Steven Wrappe, Grant Thornton
Panelists:
Laurie Dicker, BDO
Rocco Femia, Miller and Chevalier
Sayantani Ghose, KPMG
Ryan Lange, Kroll
YIN Reporter: Natalia Pierotti, Weil, Gotshal & Manges
This panel will discuss current U.S. and global transfer pricing trends in examination, litigation, rule changes, penalties, and financial reporting. It will also address the OECD report on Pillar1, Amount B and developments in the Mutual Agreement Procedure, Advance Pricing Agreement and International Assurance Programs.
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Partnerships and International Taxation
PDF (316.3 KB)
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Administration
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3/19/2024
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Moderator: Seth Green, KPMG
Panelists: Christopher Bowers, Skadden
Natasha Khemani, Deloitte
Karen Li, Attorney, Office of Chief Counsel (International), IRS (invited)
YIN reporter: Matthew Dimon, Fenwick
This panel will explore the interplay of subchapter K and various international provisions, primarily through the lens of guaranteed payments and preferred returns.
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YIN Report - Corporate International Tax Executive
PDF (58.79 KB)
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Administration
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4/8/2024
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Corporate International Tax Executives Panel
PDF (124.63 KB)
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Administration
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3/18/2024
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Moderator:
Susan Ludwigson, Morgan Stanley
Panelists:
Aditi Banerjee, Prudential
Carolina Perez Lopez, Johnson & Johnson
Tom Roesser, Microsoft
YIN Reporter: Lisanne Bergwerff, Loyens & Loeff
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Economics_partners_GLAM
PDF (217.86 KB)
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Administration
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4/3/2024
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Unpacking the IRS’ Generic Legal Advice Memorandum (“GLAM”) on Financing Transactions: A Framework for Evaluating the Effects of Implicit Support and Passive Association on the Arm’s-Length Pricing of Intercompany Loans
Sponsored by Economics Partners at Ryan
Panelists: David Suhler, Economics Partners
Brian Vincent, Economics Partners
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Primer - Update on US International Tax Treaties (
PDF (535.99 KB)
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Administration
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3/18/2024
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Moderator:
Douglas Poms, KPMG
Panelists:
Blake Bitter, Weil
Anna Moss, EY
Jeffrey Tebbs, Miller & Chevalier
Gregory Texley, Senior Technical Reviewer, Branch 1 of the Associate Chief Counsel Office (International) IRS (invited)
YIN Reporter: Sebastiann Claessen, Loyens & Loeff
This panel will provide an update on recent US tax treaty developments, including the recent US-Chile Tax Treaty, the US -Croatia Tax Treaty, a general US tax treaty update, a review of recent cases involving US income tax treaties, and recent US-Taiwan double tax relief legislation.
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Crypto Developments: Update on Hot International
PDF (717.75 KB)
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Administration
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3/19/2024
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Moderator:
Sahel Assar, Buchanan Ingersoll & Rooney
Panelists:
Jonathan Cutler, Deloitte
Erika W. Nijenhuis, US Department of Treasury (Invited)
Taylor Reid, Baker McKenzie
Anthony Tuths, KPMG
YIN Reporter: Matthew Slootsky, Baker McKenzie
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Tax Litigation/Controversy in International Taxati
PDF (421.67 KB)
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Administration
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3/18/2024
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Moderator:
Kevin Otero, Covington & Burling
Panelists:
James B. Kelly, Deputy Associate Chief Counsel International (Controversy & Litigation) I.R.S. (Invited)
Sonja Schiller, Alphabet/Google
Julia Ushakova-Stein, Fenwick
YIN Reporter: Tsitsi Mangosho, Covington & Burling
This panel will discuss the enforcement environment facing companies, including 1) the types of issues governments are raising in various tax disputes, including the resurgence of the economic substance doctrine, 2) strategies for taxpayers to implement in response, and 3) best practices for corporate tax teams to pursue to manage the risk and burden of increased scrutiny.
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International Tax Challenges Facing Family Office
PDF (831.31 KB)
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Administration
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3/18/2024
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Moderator:
Stanley Ruchelman, Ruchelman PLLC
Panelists:
Paul DePasquale, Baker McKenzie
Robert Keller, KPMG
Richard Reinhold, Special Counsel to the ACCI at I.R.S. (Invited)
Emma-Jane Weider, Maurice Turnor Gardner
YIN Reporter: Michael Bennett, Ruchelman PLLC
Historically, tax planning and compliance for family offices focused on domestic issues in the home country. But with the internationalization of commerce and international relocation of family members, large family offices now face a new series of issues at home and abroad. Some are truly domestic issues in the U.S. Others are “domestic” issues that arise in foreign countries for family members residing abroad. Still others are truly international issues encountered as family offices have expanded investment horizons on a global basis. Drawing upon experience, the panel will discuss hidden tax traps for family members in the U.S. and the U.K. and cross border tax issues commonly associated with multinational cor
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YIN Report - International Aspects of CAMT
PDF (127.18 KB)
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Administration
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4/9/2024
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International Aspects of the CAMT - Addressing Ope
PDF (328.85 KB)
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Administration
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3/18/2024
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Moderator:
Jeshua Wright, EY
Panelists:
Jason Black, PwC
John Franco, Deloitte
Taylor M. Kiessig, Special Counsel, Office of Chief Counsel (International), IRS (invited)
Gary Scanlon, KPMG
YIN Reporter: Raushan Tumabayeva, PwC
This panel will examine recent corporate alternative minimum tax (CAMT) guidance in Notice 2024-10 and Notice 2023-64, including answered and unanswered questions regarding dividends and double counting. This panel will also cover complexities taxpayers face in applying the CAMT aggregation rules to determine applicable corporation status across various structures, including those with partnerships.
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How the UN is Altering the International Tax Lands
PDF (241.66 KB)
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Administration
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3/18/2024
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Moderator:
Patricia Brown, United Nations
Panelists:
Benjamin Angel, Director for Direct Taxation, Tax coordination, Economic Analysis and Evaluation DG TAXUD (European Commission)
Yariv Brauner, University of Florida
Rasmi Das, Chief Commissioner of Income Tax, India
Kehinde Kajesomo, Deputy Director and Head of Treaties and International Tax Policy Division, Federal Inland Revenue Service, Nigeria
YIN Reporter: Logan Kincheloe, Alvarez & Marsal Tax
On 22 December 2023, the U.N. General Assembly adopted resolution 78/230, “Promotion of inclusive and effective international tax cooperation at the United Nations.” The resolution establishes an ad hoc inter-governmental committee with a mandate to develop draft terms of reference for a United Nations framework convention on international tax cooperation. For some tax practitioners, the establishment of the Committee has been unexpected and its possible implications unclear. The United Nations has, however, provided an alter
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The New 987 Regulations
PDF (308.51 KB)
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Administration
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3/18/2024
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Moderator:
Danielle Rolfes, KPMG
Panelists:
Azeka Abramoff, Special Counsel, IRS Associate Chief Counsel (International) (Invited)
Michael Mou, Deloitte
Laura Valestin, PwC
YIN Reporter: Marc Nussbaum, PwC
This panel will not provide another overview of the FEEP method included in the 2023 proposed section 987 regulations. Instead, we will focus on four key questions under the proposed regulations:
(1) what happens at transition?
(2) what happens if you terminate a QBU before the rules are finalized?
(3) how should taxpayers think about the various simplifying elections under the proposed regulations; and
(4) what are some of the remaining pain points (for example, the interaction between 987 and 988)?
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Penalties in International Tax Practice - An Updat
PDF (1.89 MB)
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Administration
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3/20/2024
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Moderator: Melissa Wiley, Lowenstein Sandler
Panelists: Pedro Corona de la Fuente, Procopio
Megan Brackney, Kostelanetz
Victor Jaramillo, Caplin & Drysdale
Larry Sannicandro, McCarter & English
YIN Reporter: Yelena Niazyan, Kostelanetz
Tax controversy professionals - including the current National Taxpayer Advocate - have been bemoaning the complex filing requirements and onerous penalties associated with international information return penalties for years. No longer limited to the notorious FBAR, the IRS has been cracking down on international information report such as Forms 5471, 5472, 3520, and 3520-A since before the pandemic. As a result, IRS Appeals has seen a deluge of cases challenging international information return penalties on the grounds of reasonable cause. This past year, it was the courts' turn to chime in. This panel will explore the recent string of international information reporting cases (including Fahry, Aroeste, and Bittner) and discuss their implica
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YIN Report - Private Equity
PDF (121.3 KB)
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Administration
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4/15/2024
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Private Equity
PDF (472.86 KB)
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Administration
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3/18/2024
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Moderator:
Rafael Kariyev, Debevoise
Panelists:
Samuel Duncan, Ropes & Gray
Susanna Parker, Cleary Gottlieb Steen & Hamilton
YIN Reporter: Melanie Xu, Ropes & Gray
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Pillar One
PDF (773.29 KB)
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Administration
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3/18/2024
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Moderator: Joshua Odintz, Holland & Knight
Panelists: Alexis Bergman, Baker Tilly
Scott Levine, Deputy Assistant Secretary, US Department of Treasury (Invited)
Gary Sprague, Baker McKenzie
YIN Reporter: Marharyta Bahno, Baker McKenzie
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International M & A: Current Developments
PDF (426.81 KB)
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Administration
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3/18/2024
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Moderator:
Candice Turner, Grant Thornton
Panelists:
Kevin M. Jacobs, Alvarez & Marsal Tax
Teisha Ruggiero, Branch Chief at IRS, Office of Chief Counsel (International)(invited)
Moshe Spinowitz, Skadden
Gordon Warnke, KPMG
YIN Reporter: Emanuel Mkrtchyan, Grant Thornton
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Pillar Two
PDF (372.39 KB)
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Administration
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3/18/2024
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Moderators:
Barbara Angus, EY
Cara Griffith, Tax Analysts
Panelists:
Mounia Benabdallah, Baker McKenzie
David Lan, KPMG
Jeffrey Mitchell, Senior Adviser, International Co-operation and Tax Administration Centre for Tax Policy and Administration (Invited)
YIN Reporter: Casey Caldwell, KPMG
This panel will provide an overview of the current status of Pillar 2. This will include an update on the current status of implementation around the world. The panel will also address the current status of and challenges presented by the peer review process, recent administrative guidance, and the GloBE information return, safe harbors, and dispute resolution.
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