3rd Annual Winter International Tax Conference
November 29-30, 2022
Virtual Conference Organized by the New York and District of Columbia Region
The 3rd Annual IFA USA Winter International Tax Conference will be held virtually on November 29 and 30, with substantive sessions for several hours each day. We are planning what is sure to be a unique, interesting, timely, and informative program, featuring
prominent speakers, over the three days.
Learning Objectives
By the end of the conference, attendees will be able to: - Understand the practical implications of the foreign tax credit regulations.
- Analyze the corporate alternative minimum taxes including understanding issues where guidance is not yet available.
- Recognize current issues in tax controversy and the government’s approach to pursing different avenues for resolution.
Instructional Delivery Method: Group Internet Based
Organizing Committee:
Peter Connors, President, IFA USA Branch – Orrick, New York
Peter Glicklich, Executive Vice President, IFA USA Branch – Davies Ward Phillips & Vineberg, New York
Josh Odintz, Regional Vice President, IFA USA District of Columbia Region – Holland & Knight, Washington DC
Candice Turner – Grant Thornton, New York
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2022 IFA USA WINTER INTERNATIONAL TAX CONFERENCE AGENDA
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| Tuesday November 29 |
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10:45 – 11:00 a.m.
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Opening Remarks |
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Peter Connors, President, IFA USA Branch
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11:00 a.m. – 12:20 p.m.
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OECD Pillar 2
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Moderator:
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Julie Joy, Bloomberg
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Panelists:
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Josh Odintz, Holland & Knight
John Peterson, OECD
Michael Plowgian, U.S. Department of the Treasury (invited)
Loren Ponds, Miller & Chevalier
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| As implementation of Pillar 2 becomes closer, we will continue our focus on the new paradigm in this special panel moderated by our Exclusive Media Sponsor Bloomberg, with input from the OECD. Our panelists will be leading experts who will
revisit the current status of its adoption and implementation around the world, and will discuss challenges for the U.S. |
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12:30 – 1:50 p.m.
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Alternative Minimum Tax
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Moderator:
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Danielle Rolfes, KPMG
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Panelists:
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Aaron Junge, PwC
Taylor Kiessig, IRS (invited)
Jeshua Wright, EY
Timothy Powell, U.S. Department of the Treasury (invited)
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| One of the most important provisions of the Inflation Reduction Act of 2022 is the addition of the Corporate Alternative Minimum Tax. This panel will explore the international implications of the new regime, including how it applies to inbound
structures, CFCs, branches, and other foreign investments, the foreign tax credit provisions, and interactions between the new regime and Pillar 2. |
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2:00 – 3:20 p.m.
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Practical implications of FTC Regs
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Moderator:
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JD Hamilton, EY
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Panelists:
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Hoon Lee, Corning Inc.
Mallory Mendrala, Deloitte
Marissa Rensen, KPMG
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| This panel will go into depth on some of the remaining uncertainties based on new FTC regs and provide some perspective on how companies are dealing with these issues as year-end approaches. |
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3:30 – 4:20 p.m.
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WIN Update and Networking Session
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| On Tuesday November 29 following the last panel session, the Women of IFA Network (WIN) will provide an update on recent and upcoming WIN activities. |
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| Wednesday November 30 |
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9:25 – 9:30 a.m.
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Day 2 Opening Remarks |
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9:30 – 10:50 a.m.
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Primer on Transfer Pricing
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Moderator:
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Lauren Ross, Covington
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Panelists:
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Jessie Coleman, KPMG
Sushovan Karki, PwC
Pamela Martin, Skadden
Michael Scanlan, Economics Partners
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| Our traditional YIN panel will provide a primer on transfer pricing useful to all members, including background relevant to issues to be considered further by our international tax controversy panel. |
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11:00 a.m. – 12:20 p.m.
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Tax Controversy
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Moderator:
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Steve Wrappe, Grant Thornton
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Panelists:
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Philip Baker, University of Oxford
Caroline Ciraolo, Kostelanetz & Fink
Thomas Greenaway, KPMG
James Kelly, IRS (invited)
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| This panel will address current IRS enforcement efforts, dispute resolution procedures and litigation of international tax issues. Particular attention will be paid to recent transfer pricing cases and government-to-government resolution. |
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12:30 – 1:20 p.m.
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Fireside Chat with Government Officials
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Jennifer Best, Acting LB&I Deputy Commissioner, Internal Revenue Service (invited)
Peter Blessing, Associate Chief Counsel (International), Internal Revenue Service (invited)
Peter Connors, President, IFA USA; Orrick, Herrington & Sutcliffe
Peter Glicklich, Executive Vice President, IFA USA; Davies Ward Phillips & Vineberg
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1:30 – 2:50 p.m.
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Private Equity
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Moderator:
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Eric Sloan, Gibson Dunn
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Panelists:
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Brian Krause, Paul Weiss
Jennifer Ray, Deloitte
Richard Reinhold, IRS (invited)
David Schnabel, Davis Polk
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| This panel will address the myriad issues that arise when subchapter K intersects (collides?) with the international tax provisions in the Internal Revenue Code, with a particular focus on how those issues affect private equity funds, their
investors, and their investments. Discussion topics will include subpart F, GILTI, PFICs, section 1248, hybridity, and treaties. |
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CLE/CPE Information
Recommended CLE credits: November 29th or 30th - 4 based on 60 min or 4.75 based on 50 min. Two full days - CLE - 8 credits based on 60 min. or 9.5 based on 50 min. in Taxation
Recommended CPE credits: November 29th or 30th - 4.8 credits. Two full days 9.5 credits - Taxes
In accordance with the standards of the National Registry of CPE Sponsors, CPE
credits have been granted based on a 50-minute hour. IFA USA National Registry Sponsor # 112000
Program Level: Basic-CPE, Intermediate to Advanced-CLE
Program prerequisites
NASBA: None
Advanced Preparation: None
USA Branch, International Fiscal Association Inc. (IFA USA) is registered with the National
Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.
Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org
National Registry Sponsor #112000
Sponsors are Welcome!
For sponsorship and exhibiting opportunities, please contact Michael Davis:
E. michaeld@ifausa.org T. (604) 739-4653.
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