IFA USA New York Region/ITI Conference

10/28/2025

Event Details

Agenda: 12:00 pm - 12:30 Registration and Lunch 12:30 pm - 1:30 pm - Panel 1 1:30 pm - 1:45 pm - Break 1:45 pm - 2:45 pm - Panel 2 2:45 pm - 3:00 pm - Break 3:00 pm - 4:00 pm - Panel 3 4:00 pm - 5:00 pm - Cocktails   Panel 1: Structuring for Special Investor Considerations This panel will discuss fund and co-investment structuring to accommodate the special tax considerations of not-for-profit, sovereign wealth, foreign pension, and other institutional investors. Participants will: • Identify and evaluate the key tax planning issues for US tax-exempt investors, including Unrelated Business Taxable Income (UBTI) and Net Investment Income (NII). • Identify and evaluate the key tax planning issues for sovereign wealth and foreign pension investors, including Section 892, Effectively Connected Income (ECI) concerns, special provisions of relevant tax treaties, and Qualified Foreign Pension Fund (QFPF) status. • Learn how asset managers develop fund structures that accommodate the unique tax needs of tax-exempt and special investors, while safeguarding the fund's ability to operate effectively and manage risk and tax compliance. Moderator: Kirstin Gallagher, KPMG Speakers: John Bennett, Simpson Thacher & Bartlett LLP Brett Fieldston, Fried Frank Nina Xue , Brookfield Asset Management Panel 2: Recent Inbound Developments  This panel will discuss recent US inbound tax developments, including OB3, notice regarding FIRPTA considerations relating to inbound F reorganizations, observations on branch profits tax rate applicable to hybrid structures, QIE look-through rules and loan origination. Participants will: • Understand the OB3 changes most relevant to inbound taxpayers and interaction with BEAT and CAMT calculations. • Identify the requirements for the new exception from FIRPTA gain recognition in certain inbound F reorganization transactions. • Evaluate “domestically-controlled” status for qualified investment entities taking into account recently released proposed regulations.  Moderator: Jennifer Lee, Davies Speakers: Nita Asher, PwC Zach Pouga , EY Panel 3: OB3 and Legislative Process This panel will discuss the international tax provisions included in the recently passed One Big Beautiful Bill Act and its impact on international tax policy in the United States. The panelists will also provide their observations on the new GILTI (NCTI), FDII (FIDDEI), and BEAT provisions. There will be some discussion of the U.S. position on Pillar 2 and how the new international tax provisions interact with the new U.S. position.  Participants will: • Gain a multinational perspective on the fast-moving changes in US tax policy. • Gain an appreciation of the interconnection between US and global tax policy. • Gain an understanding of the tax and competitive issues that companies are facing.  Moderator: Rohit Kumar ,   PwC Speakers: Alyson Lawrence ,  Johnson & Johnson Kevin Nichols ,   Uber Randi Rosenberg ,  Siemens Corporation Catherine Schultz , Business Roundtable Co-hosted by IFA USA and ITI   Registration IFA USA Members & ITI Members - $100.00 Non-Members  - $150.00 IFA USA Members must sign in to receive member pricing. If you are an ITI Member, please send an email to info@ifausa.org for discounted registration code. CPE/CLE Recommended CLE credits: 3.0 Taxation Recommended CPE credits: 3.6 Taxes In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. IFA USA National Registry Sponsor # 112000 Program Level CPE: Basic Program Level CLE: Intermediate Program prerequisites: None Advanced Preparation: None Group Live Event USA Branch, International Fiscal Association Inc. (IFA USA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org National Registry Sponsor #112000