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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 Speakers:
Incoming Ways & Means Committee Chairman, Congressman Richard E. Neal
IRS Commissioner, Charles P. Rettig


(this Agenda is preliminary and is subject to change)

Thursday February 21

8:00 a.m.

Registration opens

8:50 – 9:00 a.m.

Welcome Remarks

Sol Coffino, President, IFA USA Branch


9:10 – 10:30 a.m.

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

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


10:30 – 11:00 a.m.

Refreshment Break


11:00 a.m. – 12:00 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.


12:00 – 12:20 p.m.

IFA Congress Reporters


12:20 – 2:00 p.m.

Lunch with Keynote Speaker


2:00 – 3:15 p.m.

Taxation of Cryptocurrencies

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


3:10 – 4:15 p.m.

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


4:15 – 4:45 p.m.

Refreshment Break


4:45 – 5:30 p.m.

Beauty and the BEAT: An update on section 59A

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


6:30 – 10:00 p.m.

Reception and Dinner
Entertainment by the Capitol Steps

Friday February 22

7:30 – 8:30 a.m.

Sponsored Breakfast Seminars

8:30 – 9:30 a.m.

The View from the Hill

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


9:30 – 10:45 a.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?


10:45 – 11:00 a.m.

Refreshment Break


11:00 a.m. – 12:00 p.m.

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

12:00 – 2:00 p.m.

Lunch with Keynote Speaker

Annual Business Meeting of the IFA USA Branch and Writing Prize Award Presentation


2:00 – 3:00 p.m.

Update on Taxing the Digital Economy

The 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.


3:00 – 5:00 p.m.

Potpourri of Recent International Tax Developments



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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