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2019 Annual Conference Agenda
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47th Annual Conference of the USA Branch of the International Fiscal Association
February 21-22, 2019
The Ritz-Carlton Washington D.C.


The event includes two full days, Thursday and Friday, of substantive sessions on international tax topics, featuring prominent speakers from private practice, industry, and government. In addition, the event will include two luncheons and a gala dinner with entertainment by the Capitol Steps. Preceding the conference on Wednesday February 20 a Joint Meeting of the US and Mexico Branches of IFA will be held. A special registration fee will be offered for those who wish to attend both meetings.


Invited Special Keynote Speaker
IRS Commissioner, Charles P. Rettig



Thursday February 21

7:00 a.m.

Registration Opens

7:30 a.m.

IFA USA Branch EC, RVP and Council Breakfast

8:45 – 9:15 a.m.

Welcome Remarks

Sol Coffino, President, IFA USA Branch
Murray Clayson, President, Central IFA


9:15 – 10:15 a.m.

The In-house View of the TCJA: The Good, the Bad and the Ugly


John Deshong, Bechtel Corporation

Panelists include:

Ken Hayduk, General Dynamics

Paul Nolan, McCormick & Company, Inc.

Tom Roesser, Microsoft


10:15 – 10:45 a.m.

Refreshment Break

Sponsored by: Moore Stephens


10:45 a.m. – 12:00 p.m.

What is the Role of the Foreign Tax Credit after the TCJA?

This panel will explore Treasury and IRS guidance on all of the FTC baskets, including GILTI. How will the expense allocation rules affect taxpayers?


Moshe Spinowitz, Skadden, Arps, Slate, Meagher & Flom

Panelists include:

Caroline Ngo, McDermott Will & Emery

Thomas Plank, KPMG

Carol Tello, Eversheds Sutherland

Jason Yen, U.S. Department of the Treasury


12:00 – 2:00 p.m.

Lunch with Keynote Speaker: IRS Commissioner, Charles P. Rettig
IFA Congress Reporters


2:00 – 3:15 p.m.

Taxation of Cryptocurrencies

This panel will address how cryptocurrencies function and current tax developments.


Sahel Assar, Buchanan Ingersoll & Rooney

Panelists include:

Wendy Jackson, Deloitte

Michael Rodgers, Orrick, Herrington & Sutcliffe

Suzie Sinno, Attorney, IRS Office of the Chief Counsel (Income Tax and Accounting)

Christopher Wrobel, IRS Associate Chief Counsel (Income Tax and Accounting)


3:15 – 4:15 p.m.

Creation and Location of Intellectual Property in Light of the TCJA

A discussion of how GILTI, FDII, BEAT and changes to sections 367/482 impact the location and creation of IP. The panel will also consider developments in the EU (e.g., ATAD) and the OECD.


Joshua Richardson , Morgan, Lewis & Bockius LLP

Panelists include:

Martin Collins, PwC

Ora Grinberg, Fenwick & West

Michelle Johnson, Duff & Phelps LLC

Danielle Rolfes, KPMG


4:15 – 4:45 p.m.

Refreshment Break


4:45 – 5:45 p.m.

Beauty and the BEAT: An update on section 59A

This panel will provide an overview of the guidance on section 59A and discuss unresolved issues.


Joshua Odintz, Baker McKenzie

Panelists include:

Kevin Nichols, U.S. Department of the Treasury

Eric Sensenbrenner, Skadden, Arps, Slate, Meagher & Flom LLP

Julia Tonkovich, EY

Julia Ushakova-Stein, Fenwick & West LLP



YIN Reception
Sponsored by: Loyens & Loeff

WIN Reception
Sponsored by: EY

Reception and Dinner
Entertainment by the Capitol Steps
Sponsored by: Deloitte, Norton Rose Fulbright, and PwC

Friday February 22

7:30 – 8:30 a.m.

Economics Partners Breakfast Symposium: Attributing Profits to a Virtual Permanent Establishment: Examples and Practical  Challenges

Sponsored by: Economics Partners


8:45 – 9:45 a.m.

The View from the Hill

What can we expect from Congress over the next two years?


Chris Javens, Capitol Tax Partners

Panelists include:

Randell Gartin, Republican Chief Tax Counsel, Ways and Means Committee

Andrew Grossman, Chief Tax Counsel, Ways & Means Committee

Tiffany Smith, Chief Tax Counsel, Senate Finance Committee

Mark Warren, Senate Finance Committee Republican Chief Tax Counsel


9:45 – 10:45 a.m.

Debate: Do Tax Treaties Matter, or Has Their Time Passed?


John Harrington, Dentons

Panelists include:

Mary Bennett, Baker McKenzie

Kirsten Burmester, Caplin & Drysdale Chartered

Britt Haxton, McDermott Will & Emery

Stephen Shay, Harvard University


10:45 – 11:15 a.m.

Refreshment Break

Sponsored by: Economics Partners


11:15 a.m. – 12:15 p.m.

Global Response to the TCJA

How are other countries responding to US tax reform? Will it be a race to the bottom, or will other countries find gold in GILTI?


Cathy Schultz, National Foreign Trade Council

Panelists include:

LG "Chip" Harter, Deputy Assistant Secretary (International Tax Affairs)

Mindy Herzfeld, University of Florida

Vincent van der Lans, Loyens & Loeff N.V.

Emily Whittenburg, Shell Oil Company


12:15 – 2:00 p.m.

Lunch with Keynote Speaker

Sponsored by: Orrick

IFA USA Branch Writing Prize Award Presentation


2:00 – 3:00 p.m.

Update on Taxing the Digital Economy

This panel will address recent developments in the European Union, the OECD, and various jurisdictions. Is this a facet of destination-based taxation as at least an additional factor in apportioning taxing jurisdiction over cross border transactions based on some notion of value inputs to the aggregate income producing “transactions”? This panel will address both the jurisdiction to tax foreign suppliers based on use of digital sales platforms and also based on other means for market access.


Jeff Vanderwolk, Squire Patton Boggs

Panelists include:

Itai Grinberg, Georgetown University Law Center

Mick Knops, Loyens & Loeff N.V.

Gary Sprague, Baker McKenzie


Additional Sponsors:
KPMG – nametag lanyards
Thomson Reuters – notepads
Covington – WiFi
Duff & Phelps – app
Wolters Kluwer – pens



Sponsors are Welcome!
For sponsorship and exhibiting opportunities, please contact Michael Davis:
E. T. (604) 739-4653.

2019 Annual Conference

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2019 IFA USA Annual Conference
47th Annual Conference of the USA Branch of the International Fiscal Association
Thursday, February 21 and Friday, February 22, 2019
The Ritz-Carlton Hotel
Washington, D.C.
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