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2020 Annual Conference Agenda
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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 Keynote Speaker
IRS Commissioner, Charles P. Rettig

 

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 – 8:15 a.m.

Welcome Remarks

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

 

8:15 – 9:15 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.
 

9:15 – 10:15 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 (invited)

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.
 

10:15 – 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:

L.G. ("Chip") Harter, Deputy Assistant Secretary (International Tax Affairs), U.S. Department of Treasury (invited)

Gary Sprague, Baker & McKenzie

Robert Stack, Deloitte

YIN Reporter:

Christopher Beck, Vacovec, Mayotte & Singer

 

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:

Sean Foley, KPMG

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

Sam Maruca, Covington & Burling

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

Jason Yen, Attorney Advisor at U.S. Department of the Treasury, Office of Tax Policy

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

 
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.
 

2:45 – 3:15 p.m.

Refreshment Break

 

3:15 – 4:15 p.m.

Breakout Session 2A – International Mergers & Acquisitions Post TCJA
 

Chair:

Jay 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

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:

Rodrigo Fernandez, Economic Partners

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

Marissa K. Rensen, Special Counsel, Associate Chief Counsel International

William (Wade) Sutton, Senior Counsel Office of the International Tax Counsel U.S. Department of Treasury

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:

YIN Reception

Sponsored by Loyens & Loeff

 

WIN Reception

Sponsored by EY

 

Reception and Gala Dinner

Sponsored by

 
Friday February 28
 

7:00 – 8:00 a.m.

Breakfast Symposium

Sponsored by Economics Partners

 

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:

Daniel Lehmann, Baer & Karrer

Peter Maher, A&L Goodbody

Kathleen Russ, Travers Smith

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 (invited)

Randi Rosenberg, Siemens

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

Breakout Session 4B – Cryptocurrency

 

Chair:

Franziska Hertel, Ropes & Gray

Panelists:

Emily Fett, PwC

Suzanne Sinno, Attorney at IRS Office of Chief Counsel (invited)

Julia Ushakova-Stein, Fenwick & West

Christopher Wrobel, Special Counsel to the Associate Chief Counsel (invited)

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

 

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, Mathesons

Louise Weingrod, Johnson & Johnson Vice President Global Taxation

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, Former Taxpayer Advocate

Steve Shay, Harvard University School of Law

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 with Keynote Speaker

IFA USA Branch Writing Prize Award Presentation

Lunch sponsored by Orrick

 

1:30 – 2:30 p.m.

Breakout Session 6A – Treaty & Multilateral Instrument Update

Chair:

Brainard ("Skip") Patton,

Panelists:

Mary Bennett, Baker & McKenzie

Cathy Schultz, National Foreign Trade Council

Gretchen Sierra, Deloitte

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:

Suchi Lee, PwC

Danielle Rolfes, KPMG

Brenda Zent, Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury

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 Spinowtiz, 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 2017 Tax Act 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.
 

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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