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2021 IFA USA WINTER INTERNATIONAL TAX CONFERENCE AGENDA

10:45 – 11:00 a.m.

Peter Connors, President, IFA USA Branch

11:00 a.m. – 12:20 p.m.

Legislative Landscape in Light of Potential Tax Reform

This is a special panel held jointly with our Exclusive Media Sponsor Tax Notes

Moderator:

Benjamin Willis, Tax Analysts

Panelists:

Mindy Herzfeld, University of Florida Frederic C. Levin College of Law, and Potomac Law Group

Doug Poms, KPMG

Loren Ponds, Miller & Chevalier

Presentation
Affirmation form

Learn more about Tax Notes

12:30 – 1:50 p.m.

International Partnership Planning Issues

Moderator:

Prae Kriengwatana, PwC

Panelists:

Jennifer Alexander, Deloitte

Kimberly Blanchard, Weil, Gotshal & Manges

Melinda Harvey, IRS (invited)

Edward Tracy Jr., IRS (invited)

Discussions on the developments around international tax partnership rules and potential traps for the unwary that arise with cross-border partnership structures, as well as updates on international partnership compliance requirements.

Presentation
Affirmation form

2:00 – 3:20 p.m.

Moderator:

Pamela Fuller, Tully Rinckney; Zahn Law

Panelists:

Rebecca Lee, PwC

Michael Shulman, Shearman & Sterling

Lawrence Zlatkin, Coinbase Inc.

Presentation
Affirmation form

9:25 – 9:30 a.m.

9:30 – 10:50 a.m.

YIN Primer – US Taxation of IP Rights

Presenter:

Brainard (Skip) Patton, Boston University School of Law

YIN representative:

Alyssa Pratt, Foley Hoag LLC

In-depth review of US rules for taxing income from IP, focusing on FDII, GILTI, and related foreign tax credit issues.

Presentation
Affirmation form

11:00 a.m. – 12:20 p.m.

IP Migration in the Age of Uncertainty

Sponsored by Baker McKenzie

Moderator:

David Noren, McDermott Will & Emery

Panelists:

Larissa Neumann, Fenwick & West

Gretchen Sierra, Deloitte

Gary Sprague, Baker McKenzie

This panel will consider IP location and related decision making in an evolving tax policy landscape. Topics will include integration of acquired IP, the role of cost-sharing arrangements, advance pricing agreements, and the impact of new jurisdictional nexus requirements for foreign tax credit purposes.

Presentation
Affirmation form

12:30 – 1:50 p.m.

LB&I Hot Topics in Tax Controversy

Sponsored by Covington

Moderator:

Josh Odintz, Holland & Knight

Panelists:

Jennifer Best, IRS (invited)

John Hinding, IRS (invited)

Kat Gregor, Ropes & Gray

Lauren Ann Ross, Covington & Burling

Presentation
Affirmation form

10:45 – 11:00 a.m.

11:00 a.m. – 12:20 p.m.

Ethical Issues in International Tax Practice

Panelists:

Megan Brackney, Kostelanetz & Fink

Scott Michel, Caplin & Drysdale

Diane Ring, Boston College Law School

International tax practitioners frequently grapple with ethical questions arising from representing clients in both tax planning and tax controversy matters. These issues include conflicts of interest, due diligence, questions over privilege and confidentiality, tax return reporting and disclosure matters, and advice to taxpayers who have engaged in non-compliance. Such questions raise issues both under the applicable disciplinary rules and IRS Circular 230. The panelists will discuss the landscape of ethical rules and work through a series of hypotheticals that frame the relevant issues and provide practical and instructive guidance.

Presentation
Affirmation form

12:30 – 1:20 p.m.

Guests:

Itai Grinberg, Deputy Assistant Secretary for Multilateral Tax, Office of Tax Policy, U.S. Department of the Treasury (invited)

Jose Murillo, Deputy Assistant Secretary, International Tax Affairs, U.S. Department of the Treasury (invited)

Interviewers:

Peter Connors, Orrick, Herrington & Sutcliffe

Peter Glicklich, Davies Ward Phillips & Vineberg

1:30 – 2:50 p.m.

Moderator:

Bob Stack, Deloitte

Panelists:

Mary Bennett, Baker McKenzie

Felicie Bonnet, OECD

Presentation
Affirmation form

2:50 – 3:30 p.m.

WIN Update and Networking Event

Sponsored by Grant Thornton

Join us to find out what is happening in WIN (Women's IFA Network) and how to get involved.