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2020 Annual Conference Agenda
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KPMG

 

48th Annual Conference of the USA Branch of the International Fiscal Association
February 27-28, 2020
The Westin Copley Place, Boston

 

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. Preceding the conference on Wednesday February 26 a Joint Meeting of the US and Canada Branches of IFA will be held. A special registration fee will be offered for those who wish to attend both meetings.

 

Special Luncheon Keynote Speakers
IRS Commissioner, Charles P. Rettig
Michael Keen, Deputy Director of the International Monetary Fund Fiscal Affairs Department

 

2020 IFA USA ANNUAL CONFERENCE AGENDA

Thursday February 27
 

7:00 a.m.

Registration Opens
 

7:00 – 8:00 a.m.

IFA USA Branch EC, RVP and Council Breakfast
 

8:00 – 8:30 a.m.

Welcome Remarks

Sol Coffino, President, IFA USA Branch
Murray Clayson, President, Central IFA
Ken Vacovec, Chair, 2020 Annual Conference

 

8:30 – 9:30 a.m.

Plenary Session – Technology Panel
 

Chair:

Brigitte Muehlmann, Babson College

Panelists:

Alex ("Sandy") Pentland, MIT Professor, Media Lab Co-founder

Jeffrey Saviano, EY Global Tax Innovation Leader, MIT Connection Science Fellow, Co-lead of MIT/EY

The objective of the technology session is to offer a peek “under the hood” in connection with the technology issues that affect the taxation of the digital economy and current tax system improvement efforts. The session will start with a brief primer on the mechanics of the digital economy, followed by dynamics that complicate digital taxation, such as economics of two-sided markets, as well as the increasingly blurred lines between products, services and software. It will then turn to how advanced technology tools can be employed to classify transactions, assets, people, etc. to detect tax data inaccuracies, and to predict tax outcomes.
 

9:30 – 10:30 a.m.

Plenary Session – Unilateral Approaches to Taxation of the Digital Economy – Threshold Nexus, Cloud Classification, and Digital Service Taxes ("DST's")
 

Chair:

Matt Schnall, WilmerHale

Panelists:

Peter Blessing, Associate Chief Counsel International, Office of Chief Counsel

Olivier Dauchez, Gide Loyrette Nouel

Carol Tello, Eversheds Sutherland

This panel will discuss three issues facing individual tax jurisdictions in adapting tax rules to the digital economy – nexus, classification, and apportionment. The panel will focus specifically on the use of threshold nexus rules in U.S., state taxation, the classification of cloud solutions under Proposed Treas. Reg. §1.861-19, and the recently enacted French Digital Services Tax.
 

10:30 – 11:00 a.m.

Refreshment Break

 

11:00 a.m. – 12:15 p.m.

Plenary Session – OECD Proposals for Taxing the Digital Economy
 

Chair:

Stephen Shay, Harvard University

Panelists:

Gary Sprague, Baker & McKenzie

Robert Stack, Deloitte

YIN Reporter:

Christopher Beck, Vacovec, Mayotte & Singer

This panel will review the OECD/Inclusive Framework’s efforts to address international taxation of the digital economy, including OECD Secretariat’s “Unified Framework” proposal to shift allocation of taxing rights to market countries and “GloBE” minimum tax proposal. The panel will seek to illuminate interests of the various stakeholders (the United States, other countries and multinational businesses) and evaluate the state of the project in terms of tax policy, domestic and global politics and business practicality.
 

12:15 – 1:45 p.m.

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

 

1:45 – 2:45 p.m.

Breakout Session 1A – Transfer Pricing Panel

 

Chair:

Jill Weise, Duff & Phelps

Panelists:

Jennifer Best, LB&I Director, Treaty and Transfer Pricing Operations Practice Area, Internal Revenue Service

Sean Foley, KPMG

Sam Maruca, Covington & Burling

YIN Reporter:

Zachary Held, Duff & Phelps

The panel will discuss recent developments in transfer pricing and how these developments impact transfer pricing in practice. Topics will include: ICAP 2.0, Ways to improve 6662 documentation; Impact of TCJA, Altera – amended returns or catch up payments for stock based compensation, Spontaneous exchange – APA, Impact and experience since the January 2018 directives, and BEPS Update – Pillar I and Pillar 2.
 

Breakout Session 1B – The FTC in a Post-TCJA World

 

Chair:

Douglas Stransky, Sullivan & Worcester

Panelists:

Barbara Felker, Internal Revenue Service, Chief Branch 3

Dirk Suringa, Covington & Burling

Treavor Weeden, PwC

The TCJA repealed the deemed-paid credit under Code Section 902, modified the deemed-paid credit rules under Section 960 and added separate foreign tax credit limitation categories for foreign branch income and Global Intangible Low-Tax Income (GILTI). In addition, the TCJA changed the calculation of taxable income for purposes of the Foreign Tax Credit limitation by disregarding certain expenses and repealing the use of fair market value method for allocating interest expense. This session will examine the new post-TCJA foreign tax credit regulations and consider how the rules work in light of the various regulations and consider how the new rules work in light of the various types of foreign income categories and credit limitations in a post-TCJA world.
 

1:45 – 5:00 p.m.

Special Breakout Session 1C – MIT Media Lab Visit

 

Alex ("Sandy") Pentland, MIT Professor, Media Lab Co-founder

Jeffrey Saviano, EY Global Tax Innovation Leader, MIT Connection Science Fellow, Co-lead of MIT/EY

Sandy Pentland, MIT, and Jeffrey Saviano, EY, inviting up to 50 conference participants to a unique full-afternoon breakout session at the MIT Media Lab. The break-out session will address the application of advanced technologies – and data analysis – to solve complex tax problems within both the private and public sectors, and, how those tax problems significantly impact businesses and tax authorities. Click here to learn more

 

2:45 – 3:15 p.m.

Refreshment Break

 

3:15 – 4:15 p.m.

Breakout Session 2A – International Mergers & Acquisitions Post TCJA
 

Chair:

Jason Tata, KPMG

Panelists:

John Merrick, Internal Revenue Service, Office of Chief Counsel

Larissa Neumann, Fenwick & West

James Tobin, EY

YIN Reporter:

Alex Farr, Weil, Gotshal & Manges

This panel will discuss the latest developments in cross-border mergers and acquisitions with a focus on the impact of TCJA on transaction structures and post-transaction integration. The discussion will consider the impact of the rules and recent guidance on GILTI, FDII, BEAT, Section 958(b)(4) attribution, cash repatriation, and 163(j) on typical transaction structures.
 
Breakout Session 2B – Controversy Panel
 

Chair:

Thomas Greenaway, KPMG

Panelists:

Robert Hanson, EY

Brian Kittle, Mayer Brown

Daniel Nir, Duff & Phelps

YIN Reporter:

Michael Berbari, Duff & Phelps

This panel will present an overview of current issues and trends in international tax controversy. The panelists will discuss how both taxpayers and the IRS are confronting uncertainties around tax reform implementation, including §965 calculations, transition-period planning, and other issues. Transfer pricing controversies have multiplied recently. The panel will offer an overview of current cases and trends in U.S. transfer pricing disputes, both administrative and in litigation.
 

4:15 – 5:15 p.m.

Breakout Session 3A – BEAT & GILTI Guidance: A Leap Forward?
 

Chair:

Colleen O’Neill, EY

Panelists:

Pedro Corona de la Fuente, Procopio, Cory Hargreaves & Savitch

Rodrigo Fernandez, Economic Partners

Marissa Rensen, Special Counsel, Associate Chief Counsel International

YIN Reporter:

Lukas Kutilek, Weil, Gotshal & Manges

The panel will cover the burning question on everyone’s mind: will taxpayers need the extra day in leap year to contend with the new guidance? The discussion will address the 2019 regulations related to BEAT and GILTI, including elections and planning available to potentially mitigate the impact of both.
 
Breakout Session 3B – Partnerships, Subchapter S and High Net Worth Individuals Post-TCJA
 

Chair:

Arthur Kerr, Vacovec, Mayotte & Singer

Panelists:

Jennifer Alexander, Deloitte

Scott Harty, Alston & Bird

Barbara Rasch, KPMG

This panel will discuss the impact of TCJA on partnerships, Subchapter S and high net worth individuals including 962 elections, and the repeal of 958(b)(4), and Smith v. Commissioner.
 
 

Evening:

5:15 – 6:00: YIN Reception

Sponsored by Loyens & Loeff

 

6:00 – 6:45: WIN Reception

Sponsored by EY

 

6:15 – 11:00: Gala Evening at the Fairmont Copley Plaza Hotel

       6:15 – 7:15: Cocktail Reception

       7:15 – 11:00: Dinner

Sponsored by

 
Friday February 28
 

7:00 – 8:00 a.m.

Breakfast Session – Commercial Reasonableness, Transactional Evidence, and the Arm’s Length Standard: Recent Developments and Experience

Sponsored by Economics Partners - A Ryan Company

 

Speakers:

Bryan Daughtery, Economics Partners - A Ryan Company

David Suhler, Economics Partners - A Ryan Company

An increasingly common question to arise in transfer pricing cases is whether third parties do actually enter into similar transactions in the open market. We review these developments in light of the history of the arm’s length standard and recent guidance from tax authorities and the OECD, and examine implications for the use of transactional data in designing and documenting intercompany transactions.

 

Click here to RSVP for this breakfast

 

8:00 – 8:15 a.m.

Welcome Remarks

Ken Vacovec, Chair, 2020 Conference
Josh Richardson, Chair, 2021 Conference

 

8:15 – 9:30 a.m.

Plenary Session – Post Brexit European Tax Planning
 

Chair:

Vincent Van Der Lans, Loyens & Loeff

Panelists:

Serge Huysmans, EY

Daniel Lehmann, Baer & Karrer

Peter Maher, A&L Goodbody

Kathleen Russ, Travers Smith

YIN Reporter:

Marlous Verhoog, Loyens & Loeff

Discussion regarding alternative European headquarter jurisdictions as U.S. multi-nationals face Brexit.
 

9:30 – 10:30 a.m.

Breakout Session 4A – Corporate Tax Executives

 

Chair:

Mark Organisak, Vertex

Panelists:

Mark Colabella, Dell Technologies

David Paul, American Honda Motors

Tom Roesser, Microsoft

Randi Rosenberg, Siemens

Issues confronting and concerning U.S. tax executives in light of TJCA and OECD actions, etc.
 

Breakout Session 4B – Taxation of Cryptocurrencies

 

Chair:

Franziska Hertel, Ropes & Gray

Panelists:

Julie Hogan Rodgers, WilmerHale

Suzanne Sinno, Attorney at IRS Office of Chief Counsel

Julia Ushakova-Stein, Fenwick & West

Christopher Wrobel, Special Counsel to the Associate Chief Counsel

This panel will address current tax developments for cryptocurrencies, including valuation and domestic and international tax considerations.
 

10:30 – 11:00 a.m.

Refreshment Break

Sponsored by Economics Partners - A Ryan Company

 

11:00 a.m. – 12:00 p.m.

Breakout Session 5A – Life Science Panel

Chair:

David Saltzman, Ropes & Gray

Panelists:

Pascal Hinny, Lenz & Staehelin

Mark O’Sullivan, Matheson

Louise Weingrod, Johnson & Johnson Vice President Global Taxation

YIN Reporter:

Chris Shim, Ropes & Gray

The panel will explore the evolving U.S. and global tax policy ecosystem impacting innovation in the life science industry. Topics include R&D allocation and capitalization rules, Pillar 1, Pillar 2 and super-deductions/innovation boxes.
 
Breakout Session 5B – Taxpayer Advocate & International Taxpayer Rights

Chair:

Joshua Odintz, Baker McKenzie

Panelists:

Nina Olson, Executive Director, Center for Taxpayer Rights

Stephen Shay, Harvard University

This panel will discuss the management of data by governments and taxpayers in a global tax system. In the case of global, coordinated audits, how do taxpayers and tax authorities address the sharing of tax return information? How do governments share information outside of coordinated audits? Should taxpayers be concerned by the management of their bank account information under the Foreign Account Tax Compliance Act (“FACTA”) and the Common Reporting Standard? How are taxpayers addressing the transmission of massive amounts of data to governments? Do privacy protections matter?
 

12:00 – 1:30 p.m.

Lunch

  • IFA USA Branch Writing Prize Award Presentation
  • IFA USA Branch Annual Members' Business Meeting
  • IFA USA Incoming President, Carol Tello
  • Keynote Speaker: Michael Keen, Deputy Director of the International Monetary Fund Fiscal Affairs Department who will speak on "How the TCJA is affecting other country tax systems"

Lunch sponsored by Orrick

 

1:30 – 2:30 p.m.

Breakout Session 6A – Treaty & Multilateral Instrument Update

Chair:

Brainard ("Skip") Patton, Boston University School of Law

Panelists:

Mary Bennett, Baker & McKenzie

Harrison Cohen, Deloitte

Cathy Schultz, National Foreign Trade Council

Treaty update, focusing on recent protocols, OECD Pillar One and Pillar Two proposals, MLI developments including a possible true multilateral treaty, and BEAT & GILTI implications.

 

Breakout Session 6B – Regulatory Update

Chair:

Lewis Greenwald, DLA Piper

Panelists:

Kevin M. Jacobs, Alvarez & Marsal Taxand, LLC

Shi-Chieh ("Suchi") Lee, PwC

Danielle Rolfes, KPMG

An unprecedented volume of regulatory guidance was issued in 2019 (GILTI, FDII, BEAT), and more is anticipated in 2020. This panel will survey the year that was and discuss the 2019/2020 regulatory guidance not covered by other panels – the anti-hybrid guidance and the regulations under sections 163(j), 245A, 385, 901(m) and 987.

 

2:30 – 3:00 p.m.

Refreshment Break

 

3:00 – 4:00 p.m.

Plenary Session – After the Golden Age of U.S. International Tax Planning, What’s Next?

Sponsored by Fenwick & West

 

Chair:

Ameek Ponda, Sullivan & Worcester

Panelists:

Ron Dabrowski, KPMG

William Skinner, Fenwick & West

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

YIN Reporter:

Rita Ryan, Vacovec, Mayotte & Singer

Some would describe the last two or three decades as the Golden Age of US International Tax Planning on account of mega-trends such as inversions, repatriations, and intellectual property migrations. But the TJCA and OECD efforts have changed the terrain dramatically. What remains, if anything, of these older mega-trends, and what will be the mega-trends of the brave, new world that we now inhabit? This panel will cover the mega-trends of international tax planning’s past, present and future tax planning in a post TCJA and OECD environment.
 

4:00 – 5:00 p.m.

Plenary Session – Latest Transfer Pricing Operational Approach – UK Tax Authority Perspective

 

Chair:

Philip Martinos, PwC

Panelists:

Kevin Brown, PwC

Mark Carnduff, HMRC

Chris Palmer, HMRC

Richard Steele, HMRC

Senior officials from the UK Tax Authority, HM Revenue & Customs (“HMRC”), will present on the latest operational approach to Transfer Pricing. In particular, HMRC will talk through the background to this latest approach to Transfer Pricing, why now and how the Diverted Profits Tax and the Profit Diversion Compliance Facility, a new co-operative compliance initiative, fits into this. There will then be a panel discussion led by Philip Martinos, PwC UK, with the opportunity for questions from the audience.

 

Additional sponsors include:

Lanyards sponsored by KPMG

WiFi sponsored by Covington

App sponsored by Duff & Phelps

WIN Salon sponsored by Grant Thornton

Delegate Pens sponsored by Wolters Kluwer

 
 

 


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


2020 Annual Conference

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2020 IFA USA Annual Conference
48th Annual Conference of the USA Branch of the International Fiscal Association
Thursday, February 27 and Friday, February 28, 2020
The Westin Hotel
Boston, MA
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