2025_conf

Conference Program

Thursday, 11th
Friday, 12th

9:15am-9:30am

Welcome

Panel 1
9:30am-10:30am

Compliance

Description to come.

Learning objectives:

Speakers:

Karen Cate, IRS

Liliana Galindo, Chief Tax Officer

Manuela Lutze, PwC

Jason Smyczek, Deloitte

Neelu Nehrotra

Moderator

Panel 2
10:30am-11:30am

Controversy & Cases

Recent cases and their aftermath (Loper Bright/CornerPost, 965, transfer pricing)

Learning objectives:

Speakers:

Nikole Flax, PwC

James Kelly, ACCI

Mike Desmond

Moderator

Miller & Chevalier

11:30am-11:45am

Break

11:45am-12:30am

Keynote

Rebecca Burch

Moderator

U.S. Department of Treasury Deputy Assistant Secretary (International Tax Affairs)

Panel 3
12:30am-1:30pm

Foreign Tax Credit After OBBBA

The foreign tax credit (FTC) rules continue to evolve in the wake of the OBBBA. This panel will examine the changes to the FTC regime and limitation computations, with a focus on how statutory amendments interact with existing rules on sourcing and expense apportionment. The discussion will highlight practical considerations for U.S. multinationals when modeling FTC positions and mitigating double taxation.

Learning objectives:

Learn how OBBBA provisions have reshaped the FTC rules.
Analyze the effect of the OBBBA changes on the FTC regime and limitation calculations.
Apply practical considerations to model FTC outcomes.

Speakers:

Shae Qian, Covington

Gretchen Sierra, Deloitte

Laura Shi, ACCI: Branch 3

Deborah Tarwasokono, Attorney-Advisor at the U.S. Department of the Treasury

Elizabeth Nelson

Moderator

PwC

1:30pm-1:45pm

Break

Panel 4
1:45pm-2:45pm

How OBBBA, Pillar 2 changes and tariff policy are impacting global supply chains

This panel will examine the interplay of global tax law and trade policy changes and the resulting impact on supply chains. Balancing tax and tariff considerations often requires examination of all value drivers, including the location of manufacturing operations, intangible property (IP) structuring, transaction flows and available incentives. Any of these potential changes is likely to impact US tax considerations (FDDEI, BEAT, foreign tax credits), product valuation for tariff purposes and application of Pillar 2.

Learning objectives:

Recognizing that physical supply chain changes likely have both tax and tariff considerations.
Recognizing that intangible property structuring similarly has both tax and tariff considerations.
Understanding the potential supply chain impact of the key US international tax changes, particularly the export incentive regime (FDDEI).

Speakers:

Gabe Gartner, PwC

David Paul, American Honda

Patrick Stodel, VP of Tax - West Pharmaceuticals

Stephen Bates

Moderator

Panel 5
2:45pm-3:45pm

Partnerships and PE funds

TBD

Speakers:

Mallory Mendrala, IRS Office of Chief Counsel

Mark Melton, Holland & Knight

Amanda Nussbaum, Proskauer

Devon Bodoh

Moderator

Weil

3:45pm-4:00pm

Closing remarks

4:00pm-5:00pm

WIN Networking

9:15am-9:30am

Welcome

Panel 5
9:30am-10:30am

Tax Treaty Landscape: Current Developments and Insights

This panel session will examine important developments shaping the global tax treaty environment. Our discussion will offer a timely update on the US treaty program, spotlighting recent and ongoing negotiations, and explore the dynamic international context shaped by the OECD’s program of work and the United Nations’ evolving tax agenda as it relates to tax treaties and dispute resolution mechanisms. (The panel will also offer an update on the activities and priorities of the US competent authority office, offering guidance for practitioners navigating mutual agreement procedures and other forms of international tax dispute resolution.)

Learning objectives:

Identify and explain the latest trends and developments in US tax treaty negotiations and implementation.
Assess the impact of OECD and UN initiatives on the interpretation and administration of tax agreements, including potential areas of conflict or divergence.
Evaluate practical strategies for navigating dispute resolution under tax treaties and bilateral agreements, making use of updates from the competent authority office.

Speakers:

Arlene Fitzpatrick, EY

Blazej Kuzniacki, PwC (NL)

Elena Virgadamo, International Tax Counsel, US Department of Treasury

Quyen Huynh

Moderator

KPMG

Panel 6
10:30am-11:30am

Pillar 2: Latest Developments, Future Outlook and Practical Implications

This panel will explore the latest multilateral activity around the Pillar 2 global minimum tax regime, including the discussions in the Inclusive Framework as well as other government groups such as the G7, G20, European Union and United Nations. It also will examine the current state of Pillar 2 implementation in jurisdictions around the world. Panelists will provide their perspectives on the outlook for Pillar 2 in the coming years, with a focus on the practical implications for businesses.

Learning Objectives

Understand the ongoing policy discussions relating to Pillar 2
Evaluate the current state of Pillar 2 implementation around the world
Assess the future outlook for Pillar 2 and how businesses can prepare

Speakers:

Patrick Brown, PwC

Jeff Mitchell, Senior Advisor, OECD

Danielle Rolfes, KPMG

Isaac Wood, Office of Tax Policy at U.S. Department of the Treasury

Barbara Angus

Moderator

11:30am-11:45am

Break

11:45am-12:30pm

Fireside

TBD

Larry Pounders

Moderator

Tax Counsel, US House Ways and Means Committee

Panel 7
12:30pm-1:30pm

Ethics: Emerging Trends in the Standards of Tax Practice

TBD

Speakers:

Alexis Bergman, Crowe

Paulus Merks, HVK Stevens

Diane Ring, Boston College

Mike Lebovitz

Moderator

Eversheds

1:30pm-1:45pm

Break

Panel 8
1:45pm-2:45pm

Legislation

TBD

Learning objectives:

Speakers:

Josh Odintz, Holland & Knight

Loren Ponds, Skadden