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2023 IFA USA Annual Conference
51st Annual Conference of the USA Branch of the International Fiscal Association
Thursday, April 27 and Friday, April 28, 2023
The Ritz-Carlton Chicago Hotel
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Agenda_2023 Annual Conference - Chicago
PDF (217.06 KB)
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Administration
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4/9/2024
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Video: OECD Pillar One and Pillar Two Link
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Administration
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11/16/2023
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Moderator:
Josh Odintz, Holland & Knight
Panelists:
Mindy Herzfeld, University of Florida
Quyen Huynh, KPMG
Jeffrey G. Mitchell, OECD
Reporter: Arjun Ghosh, Caplin & Drysdale
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PDF: OECD Pillar One and Pillar Two
PDF (917.08 KB)
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Administration
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5/30/2023
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Moderator:
Josh Odintz, Holland & Knight
Panelists:
Mindy Herzfeld, University of Florida
Quyen Huynh, KPMG
Jeffrey G. Mitchell, OECD
Reporter: Arjun Ghosh, Caplin & Drysdale
In this interactive session, the panel will discuss the current state of OECD Pillars One and Two as well as the status of various countries on their respective implementation policies. Among other issues, the panel will focus on the status and implementation of the EU Directive on Pillar Two, whether and when the US will implement part or all of Pillar Two, the current state of Pillar One’s Amount A, and whether Pillar One’s Amount B can be revised to help global businesses achieve certainty.
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Video: OECD Pillar Two – What Do We Do Now? Link
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Administration
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5/30/2023
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Moderator:
Phil Ramstetter, PwC
Panelists:
Tadd Fowler, Procter & Gamble
Mark Gasbarra, Forte International Tax
Michiel Schul, Loyens & Loeff
Jason Yen, EY
Reporter: Jonneke Dijkstra, Loyens & Loeff
In this session, the panel will discuss the practical issues related to the implementation of Pillar Two, including common technical questions impacting the calculation, data requirements and data strategy, organizational design and approach, evaluation of existing and future foreign legal entity structures, considerations for M&A and post-deal integration, and impacts on inter-company financing and Treasury functions.
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PDF: OECD Pillar Two – What Do We Do Now?
PDF (531.09 KB)
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Administration
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5/30/2023
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Moderator:
Phil Ramstetter, PwC
Panelists:
Tadd Fowler, Procter & Gamble
Mark Gasbarra, Forte International Tax
Michiel Schul, Loyens & Loeff
Jason Yen, EY
Reporter: Jonneke Dijkstra, Loyens & Loeff
In this session, the panel will discuss the practical issues related to the implementation of Pillar Two, including common technical questions impacting the calculation, data requirements and data strategy, organizational design and approach, evaluation of existing and future foreign legal entity structures, considerations for M&A and post-deal integration, and impacts on inter-company financing and Treasury functions.
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Video: The Inflation Reduction Act of 2022 Link
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Administration
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5/30/2023
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Moderator:
Cara Griffith, Tax Analysts
Panelists:
Taylor Kiessig, Special Counsel, Office of Associate Chief Counsel International, Internal Revenue Service (Invited)
Kara Mungovan, Davis Polk
Danielle Rolfes, KPMG
Gretchen Sierra, Deloitte
Brenda Zent, Special Advisor, Office of International Tax Counsel, U.S. Department of the Treasury (invited)
Reporter: Elena Madaj, KPMG
In this session, the panel will discuss the newly introduced Corporate Alternative Minimum Tax regime for large corporations, Notice 2023-7, and open questions raised by the guidance. The panel will also discuss the excise tax on stock repurchases and unresolved issues raised in Notice 2023-2.
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PDF: The Inflation Reduction Act of 2022
PDF (448.41 KB)
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Administration
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5/30/2023
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Moderator:
Cara Griffith, Tax Analysts
Panelists:
Taylor Kiessig, Special Counsel, Office of Associate Chief Counsel International, Internal Revenue Service (Invited)
Kara Mungovan, Davis Polk
Danielle Rolfes, KPMG
Gretchen Sierra, Deloitte
Brenda Zent, Special Advisor, Office of International Tax Counsel, U.S. Department of the Treasury (invited)
Reporter: Elena Madaj, KPMG
In this session, the panel will discuss the newly introduced Corporate Alternative Minimum Tax regime for large corporations, Notice 2023-7, and open questions raised by the guidance. The panel will also discuss the excise tax on stock repurchases and unresolved issues raised in Notice 2023-2.
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Video: So, You Want to Expatriate... Link
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Administration
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5/30/2023
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Moderator:
Alan Winston Granwell, Holland & Knight
Panelists:
Rosy Lor, BDO USA
Linda Rahal, Trow & Rahal, PC
Reporter: Marc André Gaudreau Duval, Davies
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PDF: So, You Want to Expatriate...
PDF (938.72 KB)
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Administration
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5/30/2023
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Moderator:
Alan Winston Granwell, Holland & Knight
Panelists:
Rosy Lor, BDO USA
Linda Rahal, Trow & Rahal, PC
Reporter: Marc André Gaudreau Duval, Davies
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Video: Evolving Taxation of Cryptocurrency, NFTs.. Link
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Administration
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5/30/2023
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Moderator:
Sahel Assar, Buchanan Ingersoll, & Rooney
Panelists:
Garrett L. Brodeur, Kostelanetz
Miles Fuller, TaxBit
Erika W. Nijenhuis, Senior Counsel, Office of Tax Policy, U.S. Treasury Department (Invited)
Ben Symons, The 36 Group
Reporter: Sean McElroy, Fenwick
In this session, the panel will address the expansive and inconsistent rules of engagement pertaining to taxation of assets derived from blockchain technology, including, tax treatment and consequences as well as reporting requirements. The panel will address the need for global consistency and coordination among tax administrators in the United States and abroad (special focus on CARF, CRS, FATCA, exchange of information treaties, among others) to ensure transparency.
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PDF: Evolving Taxation of Cryptocurrency, NFTs...
PDF (417.68 KB)
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Administration
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5/30/2023
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Moderator:
Sahel Assar, Buchanan Ingersoll, & Rooney
Panelists:
Garrett L. Brodeur, Kostelanetz
Miles Fuller, TaxBit
Erika W. Nijenhuis, Senior Counsel, Office of Tax Policy, U.S. Treasury Department (Invited)
Ben Symons, The 36 Group
Reporter: Sean McElroy, Fenwick
In this session, the panel will address the expansive and inconsistent rules of engagement pertaining to taxation of assets derived from blockchain technology, including, tax treatment and consequences as well as reporting requirements. The panel will address the need for global consistency and coordination among tax administrators in the United States and abroad (special focus on CARF, CRS, FATCA, exchange of information treaties, among others) to ensure transparency.
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Video: Tax Controversy Link
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Administration
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5/30/2023
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Moderator:
Larissa Neumann, Fenwick
Panelists:
James B. Kelly, Deputy Associate Chief Counsel International (Controversy & Litigation) (Invited)
Tom Linguanti, Morgan Lewis
Sonja Schiller, Alphabet/Google
Reporter: Matthew Dimon, Fenwick
In this Tax Controversy session, panelists will share their views on recent controversy cases and litigation trends and provide strategies on how to manage and resolve disputes efficiently and effectively.
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PDF: Tax Controversy
PDF (297.11 KB)
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Administration
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5/30/2023
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Moderator:
Larissa Neumann, Fenwick
Panelists:
James B. Kelly, Deputy Associate Chief Counsel International (Controversy & Litigation) (Invited)
Tom Linguanti, Morgan Lewis
Sonja Schiller, Alphabet/Google
Reporter: Matthew Dimon, Fenwick
In this Tax Controversy session, panelists will share their views on recent controversy cases and litigation trends and provide strategies on how to manage and resolve disputes efficiently and effectively.
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Video: Workouts and Financial Restructuring a Busi Link
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Administration
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5/30/2023
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Moderator:
Kevin M. Jacobs, Alvarez & Marsal
Panelists:
Joe Pari, Weil, Gotshal & Manges
Anthony V. Sexton, Kirkland & Ellis
Bela Unell, KPMG
Reporter: Jamal Aquil, KPMG
This panel will discuss domestic and international tax issues, including traps for the unwary, of distressed companies as they consider restructuring their debt in or outside of bankruptcy. The discussion may cover a range of topics including: (1) when a significant modification occurs and its consequences (including potential cancellation of debt income and associated exceptions); (2) potential bankruptcy emergence alternatives, (3) the application of section 382 to controlled foreign corporations, and; (4) the role the inversion rules play in restructuring.
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PDF: Workouts and Financial Restructuring a Busine
PDF (589.41 KB)
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Administration
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5/30/2023
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Moderator:
Kevin M. Jacobs, Alvarez & Marsal
Panelists:
Joe Pari, Weil, Gotshal & Manges
Anthony V. Sexton, Kirkland & Ellis
Bela Unell, KPMG
Reporter: Jamal Aquil, KPMG
This panel will discuss domestic and international tax issues, including traps for the unwary, of distressed companies as they consider restructuring their debt in or outside of bankruptcy. The discussion may cover a range of topics including: (1) when a significant modification occurs and its consequences (including potential cancellation of debt income and associated exceptions); (2) potential bankruptcy emergence alternatives, (3) the application of section 382 to controlled foreign corporations, and; (4) the role the inversion rules play in restructuring.
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Video: Ethics-ESG: Global Tax Policy Statements Link
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Administration
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5/30/2023
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Moderator:
Brigitte W. Muehlmann, Babson College
Panelists:
Danielle Barrs, EisnerAmper
Jeff Bozell, KPMG
Cathy Schultz, Business Roundtable
Genevieve Tokić , Northwestern University Pritzker School of Law
Reporter: Bunmi Ayo-Ogunmuko, Northwestern University
This Ethics-ESG session will explore the topic of the emerging practice of issuing global tax policy statements. Global tax policy statements are an increasingly utilized tool by companies to demonstrate their commitment to environmental, social and governance (ESG) factors and responsible corporate behavior in the spirit of stakeholder capitalism. Published on companies’ websites, they outline the taxpayers’ commitment to paying their fair share of taxes in every country in which they operate. The panelists will discuss the contents of global tax policy statements, their purpose and expected benefits, and their potential implications on international tax practice.
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PDF: Ethics-ESG: Global Tax Policy Statements
PDF (3.69 MB)
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Administration
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5/30/2023
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Moderator:
Brigitte W. Muehlmann, Babson College
Panelists:
Danielle Barrs, EisnerAmper
Jeff Bozell, KPMG
Cathy Schultz, Business Roundtable
Genevieve Tokić , Northwestern University Pritzker School of Law
Reporter: Bunmi Ayo-Ogunmuko, Northwestern University
This Ethics-ESG session will explore the topic of the emerging practice of issuing global tax policy statements. Global tax policy statements are an increasingly utilized tool by companies to demonstrate their commitment to environmental, social and governance (ESG) factors and responsible corporate behavior in the spirit of stakeholder capitalism. Published on companies’ websites, they outline the taxpayers’ commitment to paying their fair share of taxes in every country in which they operate. The panelists will discuss the contents of global tax policy statements, their purpose and expected benefits, and their potential implications on international tax practice.
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Video: Primer on Tax Treaties (YIN Session) Link
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Administration
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5/30/2023
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Panelists:
Lara Banjanin, Senior Counsel, Office of Associate Chief Counsel, Internal Revenue Service (invited)
Sydnei Jones, Weil, Gotshal & Manges
Lukas Kutilek, Latham & Watkins
Olivia Long, OECD
Samira Varanasi, KPMG
Reporter: Diksha Bhatt, Baker Tilly; IFA USA YIN
In this session, the panel will provide a brief overview of the treaty approval process in the U.S. and discuss recent developments with respect to U.S. income tax treaties, including the newly signed treaty with Croatia and impact of the termination of the U.S.-Hungary Tax Treaty. With employers allowing permanent remote work from anywhere, the panel also will also address PE and nexus related issues, with a special focus on the recent OECD developments to address workforce mobility. With taxpayers relying more heavily on U.S. tax treaties to mitigate the impact of the recent FTC regulations, the panel will also discuss treaty-related challenges posed by income earned through fiscally transparent entities.
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PDF: Primer on Tax Treaties (YIN Session)
PDF (672.26 KB)
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Administration
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5/30/2023
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Panelists:
Lara Banjanin, Senior Counsel, Office of Associate Chief Counsel, Internal Revenue Service (invited)
Sydnei Jones, Weil, Gotshal & Manges
Lukas Kutilek, Latham & Watkins
Olivia Long, OECD
Samira Varanasi, KPMG
Reporter: Diksha Bhatt, Baker Tilly; IFA USA YIN
In this session, the panel will provide a brief overview of the treaty approval process in the U.S. and discuss recent developments with respect to U.S. income tax treaties, including the newly signed treaty with Croatia and impact of the termination of the U.S.-Hungary Tax Treaty. With employers allowing permanent remote work from anywhere, the panel also will also address PE and nexus related issues, with a special focus on the recent OECD developments to address workforce mobility. With taxpayers relying more heavily on U.S. tax treaties to mitigate the impact of the recent FTC regulations, the panel will also discuss treaty-related challenges posed by income earned through fiscally transparent entities.
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Video: The U.S. Foreign Tax Credit Regulations Link
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Administration
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5/30/2023
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Moderator:
Brian Jenn, McDermott, Will & Emery
Panelists:
Michael Cornett, BDO
Ninee Dewar, PwC
Teisha Ruggiero, Office of Chief Counsel (International), Internal Revenue Service (invited)
Julia Ushakova-Stein, Fenwick
Reporter: Julia Markova, PwC
In this session, the panel will discuss recent proposed foreign tax credit regulations regarding creditability of foreign taxes and certain disregarded payment transactions, outstanding issues under 2022 final foreign tax credit regulations, creditability of foreign taxes arising under Pillar 2/GloBE regimes and related issues, and foreign tax credit issues under the U.S. corporate alternative minimum tax (CAMT).
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PDF: The U.S. Foreign Tax Credit Regulations
PDF (497.92 KB)
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Administration
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5/30/2023
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Moderator:
Brian Jenn, McDermott, Will & Emery
Panelists:
Michael Cornett, BDO
Ninee Dewar, PwC
Teisha Ruggiero, Office of Chief Counsel (International), Internal Revenue Service (invited)
Julia Ushakova-Stein, Fenwick
Reporter: Julia Markova, PwC
In this session, the panel will discuss recent proposed foreign tax credit regulations regarding creditability of foreign taxes and certain disregarded payment transactions, outstanding issues under 2022 final foreign tax credit regulations, creditability of foreign taxes arising under Pillar 2/GloBE regimes and related issues, and foreign tax credit issues under the U.S. corporate alternative minimum tax (CAMT).
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Video: Transfer Pricing - Recent Updates Link
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Administration
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5/30/2023
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Moderator:
Ryan Lange, Kroll
Panelists:
Clark Armitage, Caplin & Drysdale
Kathleen Danakis, Illinois Tool Works
David Farhat, Skadden
Reporter: David Cooper, Kroll
The transfer pricing landscape has been rapidly changing and evolving over the past several years, with more changes yet to come. This panel will discuss certain important transfer pricing issues emerging as a result of these changes, as well as highlight current TP-related developments that multinationals should have on their radar.
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PDF: Transfer Pricing – Recent Updates
PDF (351.25 KB)
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Administration
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5/30/2023
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Moderator:
Ryan Lange, Kroll
Panelists:
Clark Armitage, Caplin & Drysdale
Kathleen Danakis, Illinois Tool Works
David Farhat, Skadden
Reporter: David Cooper, Kroll
The transfer pricing landscape has been rapidly changing and evolving over the past several years, with more changes yet to come. This panel will discuss certain important transfer pricing issues emerging as a result of these changes, as well as highlight current TP-related developments that multinationals should have on their radar.
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Video: Avoiding and Contesting IRS Penalties Link
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Administration
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5/30/2023
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Moderator: Melissa Wiley, Caplin & Drysdale
Panelists: Matt Cooper, Deloitte
Gwen Moore, Moore Law Group
Dan Price, Law Offices of Daniel N. Price
Reporter: Molefi McIntosh, Caplin & Drysdale
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PDF: Avoiding and Contesting IRS Penalties
PDF (971.68 KB)
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Administration
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5/30/2023
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Moderator: Melissa Wiley, Caplin & Drysdale
Panelists: Matt Cooper, Deloitte
Gwen Moore, Moore Law Group
Dan Price, Law Offices of Daniel N. Price
Reporter: Molefi McIntosh, Caplin & Drysdale
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Video: International Mergers and Acquisitions Link
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Administration
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6/7/2023
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Moderator:
Anna Voortman, EY
Panelists:
Devon Bodoh, Weil Gotshall & Manges
Diana Doyle, Latham & Watkins
Shane Kiggen, EY
Laura Williams, Office of the Associate Chief Counsel (International), Internal Revenue Service (Invited)
Reporter: Shun Tosaka, EY
This panel will cover structural trends in M&A transactions and will include a robust discussion of the impact of recent global legislation and initiatives in the deal space. Topics will range from the impact of the BEPS Pillar 2 minimum tax initiative (GLoBE); the adoption of a Corporate Alternative minimum tax in the US as well as the impact to SPACs of the 1% excise tax on stock buy backs.
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PDF: International Mergers and Acquisitions
PDF (648.7 KB)
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Administration
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5/30/2023
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Moderator:
Anna Voortman, EY
Panelists:
Devon Bodoh, Weil Gotshall & Manges
Diana Doyle, Latham & Watkins
Shane Kiggen, EY
Laura Williams, Office of the Associate Chief Counsel (International), Internal Revenue Service (Invited)
Reporter: Shun Tosaka, EY
This panel will cover structural trends in M&A transactions and will include a robust discussion of the impact of recent global legislation and initiatives in the deal space. Topics will range from the impact of the BEPS Pillar 2 minimum tax initiative (GLoBE); the adoption of a Corporate Alternative minimum tax in the US as well as the impact to SPACs of the 1% excise tax on stock buy backs.
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Video: Repatriation Planning Link
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Administration
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5/30/2023
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Moderator:
Marty Collins, PwC
Panelists:
Anna Bazula, Tax at Abbott Laboratories
Prae Kriengwatana, Tax Planning, CBRE
Daniel Luchsinger, Covington
Laura Williams, Office of the Associate Chief Counsel (International), Internal Revenue Service (Invited)
Reporter: Henry Zeng, PwC
Five-plus years after TCJA and the enactment of the U.S. participation regime, Repatriation ("Repat") is filled with minefields and is a bit mind-numbing at times. This panel will explore whether there are common themes or whether certain adjustments may be necessary in the future
Dividends, PTEP Fun and Avoiding the ER
Offshore/Onshore Cash Pools
Section 956 - Are the Gates Wide Open
IP Repatriations
FTCs: Routine Distributions, Non-routine Credits
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PDF: Repatriation Planning
PDF (564.64 KB)
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Administration
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5/30/2023
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Moderator:
Marty Collins, PwC
Panelists:
Anna Bazula, Tax at Abbott Laboratories
Prae Kriengwatana, Tax Planning, CBRE
Daniel Luchsinger, Covington
Laura Williams, Office of the Associate Chief Counsel (International), Internal Revenue Service (Invited)
Reporter: Henry Zeng, PwC
Five-plus years after TCJA and the enactment of the U.S. participation regime, Repatriation ("Repat") is filled with minefields and is a bit mind-numbing at times. This panel will explore whether there are common themes or whether certain adjustments may be necessary in the future
Dividends, PTEP Fun and Avoiding the ER
Offshore/Onshore Cash Pools
Section 956 - Are the Gates Wide Open
IP Repatriations
FTCs: Routine Distributions, Non-routine Credits
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Video: Withholding Tax and Other Inbound Topics Link
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Administration
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5/30/2023
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Moderator: Jennifer Lee, Davies Ward
Panelists: Kim Blanchard, Blanchard Tax
Michael Miller, Roberts & Holland
David Sites, Grant Thornton
Reporter: Sydnei Jones, Weil, Gotshal & Manges
The web of US tax rules applicable to inbound investment has grown increasingly broad and complicated over the last few years thanks to TCJA and Inflation Reduction Act (IRA), with ongoing regulatory guidance continuing to further complicate matters. This panel will work through several recent developments that foreign investors in the United States and their advisors should take note of, including certain Section 1446(f) developments, issues facing foreign multinational groups with respect to the new Corporate Alternative Minimum Tax (CAMT) and stock buyback excise tax introduced by the IRA, and proposed rule changes under FIRPTA in particular those affecting domestically-controlled REITs (DC REITs). The panel will also consider implications of the Tax Court’s recent decision in Rawat v. Comm’r,
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PDF: Withholding Tax and Other Inbound Topics
PDF (881.75 KB)
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Administration
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5/30/2023
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Moderator: Jennifer Lee, Davies Ward
Panelists: Kim Blanchard, Blanchard Tax
Michael Miller, Roberts & Holland
David Sites, Grant Thornton
Reporter: Sydnei Jones, Weil, Gotshal & Manges
The web of US tax rules applicable to inbound investment has grown increasingly broad and complicated over the last few years thanks to TCJA and Inflation Reduction Act (IRA), with ongoing regulatory guidance continuing to further complicate matters. This panel will work through several recent developments that foreign investors in the United States and their advisors should take note of, including certain Section 1446(f) developments, issues facing foreign multinational groups with respect to the new Corporate Alternative Minimum Tax (CAMT) and stock buyback excise tax introduced by the IRA, and proposed rule changes under FIRPTA in particular those affecting domestically-controlled REITs (DC REITs). The panel will also consider implications of the Tax Court’s recent decision in Rawat v. Comm’r,
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Video: Traps for the Unwary Link
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Administration
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5/30/2023
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Moderator:
Eric Sloan, Gibson Dunn
Panelists:
Rachel Cantor, Kirkland & Ellis
James Jennings, Gibson Dunn
Julia Skubis Weber, Baker McKenzie, Chicago
Reporter: Emily Berg, Baker McKenzie
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 both in-bound and out-bound cross border transactions and planning matters, for both multinationals and investment funds. The panel will include issues arising under section 367, 7874, GILTI, check-the-box, withholding tax issues, and more.
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PDF: Traps for the Unwary
PDF (226.08 KB)
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Administration
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5/30/2023
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Moderator:
Eric Sloan, Gibson Dunn
Panelists:
Rachel Cantor, Kirkland & Ellis
James Jennings, Gibson Dunn
Julia Skubis Weber, Baker McKenzie, Chicago
Reporter: Emily Berg, Baker McKenzie
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 both in-bound and out-bound cross border transactions and planning matters, for both multinationals and investment funds. The panel will include issues arising under section 367, 7874, GILTI, check-the-box, withholding tax issues, and more.
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