USA BRANCH ANNUAL CONFERENCE AGENDA

7:30 – 8:30 a.m.

IFA USA Branch Council Breakfast

8:45 – 9:00 a.m.

Welcome and Opening Address

Peter Connors, President, IFA USA Branch

9:00 – 10:00 a.m.

Global Tax Legislative Update

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

Moderator:

Cara Griffith, Tax Analysts

Panelists:

Barbara Angus, EY

Will Morris, PwC

Sandy Radmanesh, German Embassy Washington D.C.

Sarah Shive, Capitol Tax Partners

This panel will discuss tax legislation under consideration in the United States, European Union, and the OECD. Will countries implement the OECD pillars, and if so, when? Will the United States modify GILTI and the BEAT? What is the timeline for the OECD to finalize model rules and a convention for its proposals?
Slide Presentation

10:00 – 10:30 a.m.

Refreshment Break

10:30 – 11:30 a.m.

What’s Bothering Corporate Tax Departments?

Moderator:

John Deshong, Bechtel

Panelists:

Ken Hayduk, General Dynamics

Paul Nolan, McCormick

Tom Roesser, Microsoft

Microsoft, General Dynamics, McCormick and Bechtel will highlight their companies’ top current tax concerns in the software, government contracting, manufacturing, and services businesses and discuss how inhouse and advisory tax professionals can best advise C-suite in this time of great tax uncertainty.

11:30 – 12:45 p.m.

The Structural Soundness of Pillar II: Providing Support or Needing Support?

This panel is sponsored by PwC

Moderator:

John Harrington, Dentons

Panelists:

Chip Harter, PwC

Mindy Herzfeld, University of Florida, Frederic G. Levin College of Law

John Peterson, OECD

Bob Stack, Deloitte Tax LLP

Widespread implementation of Pillar II, or the ‘Global Anti-Base Erosion (GloBE)’ regime, would result in a fundamental reworking of international tax rules. With that goal in mind, the OECD/G20 Inclusive Framework on BEPS has released model rules and commentary, European countries are working on legislation to implement those rules, and the United States is considering changes to its GILTI regime to make it more consistent with Pillar II. However, the process of transposing a high-level ‘political agreement’ into specific legislative, regulatory, and administrative rules is fraught with questions and unexpected developments. Join this panel of former U.S. Treasury lead negotiators to the OECD and prominent commentators on BEPS as it evaluates actions taken so far regarding implementation of Pillar II and likely next steps and outcomes.
Slide Presentation

12:45 – 2:00 p.m.

Lunch

• Presentation of the IFA USA Writing Prize
  Tracy Kaye, Chair, IFA USA Academia Committee

Luncheon Speakers:

Itai Grinberg, Deputy Assistant Secretary (Multilateral Negotiations), Office of Tax Policy, U.S. Department of the Treasury (Invited)
Rebecca Kysar, Counselor, Office for Tax Policy, U.S. Department of the Treasury (Invited)

2:00 – 3:00 p.m.

Tax Planning for the Termination of Operations

Moderator:

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

Panelists:

Joe Calianno, Andersen

Martin Hunter, PwC

Shane Kiggin, EY

This panel will discuss the tax considerations associated with winding down and ceasing operations, including worthless stock losses, business transfers and other methods for jurisdictional exit of business operations.
Slide Presentation

3:00 – 3:30 p.m.

Refreshment Break

3:30 – 4:30 p.m.

Two Breakout Sessions

Crypto Assets: Rising Tide of Reporting and Other Regulatory Developments of Interest to International Tax Practitioners, Traders, Dealers, Exchanges and Blockchain Partners

This session is organized by the IFA USA Diversity & Inclusion Committee

Moderator:

Sahel Assar, Buchanan Ingersoll & Rooney; Chair, IFA USA D&I Committee

Panelists:

Bea Castaneda, Coinbase

Colby Mangels, OECD

Niklas Schmidt, Wolf Theiss

Lisa Zarlenga, Steptoe & Johnson

The discussion will focus on the following topics:

• Review and discuss the OECD’s March 22, 2022 tax reporting platform, CARF, and the ensuing public comments
• Assess CARF’s regulatory impact on market participants, including entities
• Consider CARF’s global aspects with current U.S. tax reporting initiatives
• Anticipate potential U.S. response to align reporting requirements with the OECD’s approach (ex: US Biden Green Book proposals) and discuss practical implications of CARF for U.S. exchanges.
  Slide Presentation
  

Understanding the New World of Transparency Through Expanded Reporting Requirements

Moderator:

Neelu Mehrotra, EY

Panelists:

John Hinding, Director, Cross Border Activities Practice Area, Internal Revenue Service (Invited)

Michael LaCalamito, GSK

David Paul, America Honda Motor Company

Richard Steinauer, PWC

This panel will discuss the expanded forms (ie, 5471, 1118, schedule K2/K-3) and their impacts on data gathering and process. As overall compliance efforts continue to increase, insights will be provided on how to address your compliance efficiently while meeting the reporting requirements.
Slide Presentation

4:30 – 5:30 p.m.

Two Breakout Sessions

Where is the Best Location for a Headquarters Company?

Moderator:

Larissa Neumann, Fenwick & West

Panelists:

Teresa Chen, Workday

Thomas Kelly, Deloitte Tax LLP

Jose Marcio R. Rego Filho, PwC

Vincent van der Lans, Loyens & Loeff

YIN Reporter: Ariel Love, Fenwick & West

In light of various recent developments in international tax and the growing global economy, it is important to evaluate and model out the tax implications of where various business headquarter operations are located. This panel is not just about the location of the parent company, we will also discuss important issues in acquisitions and new IP development.
Slide Presentation

YIN Report

From the Trenches: Campaigns and Cases Impacting Multinationals

Moderator:

Kat Saunders Gregor, Skadden, Arps, Slate, Meagher & Flom

Panelists:

Elizabeth Askey, Deputy Division Counsel (International), Internal Revenue Service (Invited)

Matthew Cooper, Deloitte Tax LLP

John Hinding, Director, Cross Border Activities Practice Area, Internal Revenue Service (Invited)

S. Starling Marshall, Crowell & Moring

Sonja Schiller, Netflix

6:00 – 6:30 p.m.

Networks Cocktail Receptions

WIN Cocktail Reception, sponsored by Fenwick & West

YIN Cocktail Reception, sponsored by Loyens & Loeff

6:30 – 10:00 p.m.

Reception and Gala Dinner

Featuring a dynamic performance by The Jersey Tenors!

7:30 – 8:30 a.m.

2 Concurrent Breakfast Sessions

A Brave New Foreign Tax Credit World!

This session is sponsored by Forte International Tax and supported by IFA USA YIN and WIN

Moderator:

Amie Colwell Breslow, Jones Day

Panelists:

Natalia Pierotti, Weil, Gotshal & Manges

Shae Qian, Covington & Burling

Deborah Tarwasokono, EY

FTC rules can be complex, and this panel will be a primer to explore the FTC world, including how FTCs have changed since TCJA, an overview of the newly promulgated FTC regs, issues that arise, and traps for the unwary. So whether you’re new to tax, just dipping your toe into the FTC world, or haven’t visited FTCs in a while, this panel should give you a good starting point.
Slide presentation

When should Commensurate with Income be Applied? Economic Considerations Regarding the IRS/Treasury Priority Guidance Plan

This session is sponsored by Economics Partners a Ryan Company

Panelists:

Brian Vincent, Principal, Transfer Pricing, Economics Partners a Ryan Company

Rodrigo Fernandez, Principal, Transfer Pricing, Economics Partners a Ryan Company

8:45 – 9:00 a.m.

Morning Remarks

• Short preview of new video of IFA USA Heritage Project

9:00 – 10:15 a.m.

Traps for the Wary: Cross-Border Tax Conundrums

This session is sponsored by Weil, Gotshal & Manges

Moderator:

David Saltzman, Ropes & Gray

Panelists:

Devin Bodoh, Weil, Gotshal & Manges

Taylor Kiessig, Special Counsel, Office of Chief Counsel (International), Internal Revenue Service (Invited)

Caroline Ngo, McDermott Will & Emery

Mario Salandra, Aon

Julia Ushakova-Stein, Fenwick & West

Even sophisticated tax advisors can be surprised by tax outcomes, particularly as new rules are applied both to new as well as conventional commercial situations. This panel will explore tax issues arising for practitioners advising on cross border transactions and planning matters, both for multinationals and investment funds. The panel will include issues arising under section 367, 7874, GILTI and more.
Slide presentation

10:15 – 10:45 a.m.

Refreshment Break

10:45 – 12:00 p.m.

Pillar I: The Inclusive Framework

Moderator:

Danielle Rolfes, KPMG

Panelists:

Michael Plowgian, Counselor to the Assistant Secretary for Tax Policy, U.S. Department of the Treasury, (invited)

Tom Roesser, Microsoft

Catherine Schultz, Business Roundtable

Gary Sprague, Baker McKenzie

Pillar I: The Inclusive Framework agreed to significantly revise the rules for nexus to ensure more profits are ceded to market jurisdictions. This is a once in a hundred year change to international tax that will have profound implications for potentially all multinational groups. This panel will explore the most challenging issues and how they will impact different industries.
Slide presentation

12:00 – 1:15 p.m.

Lunch

This lunch is sponsored by Orrick Herrington & Sutcliffe

• IFA USA Branch Annual General Meeting
  Peter Connors, President, IFA USA Branch

Luncheon Fireside Chat:

Peter Blessing, Associate Chief Counsel (International), Internal Revenue Service (Invited)
Nikole Flax, Large Business and International Division Commissioner, Internal Revenue Service (Invited)
Peter Connors, Orrick Herrington & Sutcliffe
Peter Glicklich, Davies Ward Phillips & Vineberg

1:15 – 2:15 p.m.

Cross-Border Partnership Planning and Developments

Moderator:

Layla Asali, Miller & Chevalier

Panelists:

Ari Berk, Deloitte Tax LLP

Andrew Gordon, Special Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service (Invited)

Monisha Santamaria, KPMG

This panel will discuss the current landscape of GILTI and Subpart F inclusions and partnerships, with an emphasis on recent regulations providing for partner-level determinations with respect to foreign corporations owned by domestic partnerships, and continued areas of uncertainty in light of the impact of these regulations on PTEP and basis adjustments. The panel will also discuss cross-border transactional issues involving partnerships and recent proposed regulations regarding PFICs and domestic partnerships.
Slide presentation

2:15 – 2:45 p.m.

Refreshment Break

2:45 – 3:45 p.m.

Final Foreign Tax Credit Regulations – Six Months In

This session is sponsored by Forte International Tax

Moderator:

Rocco Femia, Miller & Chevalier

Panelists:

Kodj Gbegnon, PwC

Isaac Wood, Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury (Invited)

Jason Yen, EY

Taxpayers and practitioners have had six months to process and work with the new standards of the final foreign tax credit regulations issued at the end of 2021. This panel will discuss select issues with the application and interpretation of these regulations, including areas where additional clarification or guidance may be considered. Specific agenda items include:

• Update on creditability issues
• Non-compulsory payment rules
• Pillar 2 taxes and the foreign tax credit
  

Slide presentation

3:45 – 4:45 p.m.

Ethics in 2022: Privilege on Trial, Practice on the Move

Moderator:

Diane Ring, Boston College

Panelists:

Megan Brackney, Kostelanetz & Fink

Amanda Leon, Caplin & Drysdale

In 2022, two core ethics issues, the availability of attorney-client privilege protection and the significance of practice limitations, demand a fresh look. The 9th Circuit rejected assertions of privilege by an international tax law firm regarding attorney-client communications involving legal and nonlegal advice. What could the court's ruling, which is now on appeal to the Supreme Court, mean for attorney-client relations? Are other protections available? How can lawyers best protect their clients going forward – and what additional concerns arise cross-border?

Also new in 2022 is the permanency of long-term hybrid and remote work. What initially emerged as a temporary pandemic response has become a workplace commitment in many firms. Now these firms need to take a careful look at practice of law limitations, in the US and beyond.
Slide presentation

4:45 p.m.

Adjourn