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USA BRANCH ANNUAL CONFERENCE AGENDA
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| Thursday March 21 |
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7:30 – 8:30 a.m.
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IFA USA Branch Council Breakfast - 10th Floor, Olympic Room 5
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8:45 – 9:00 a.m.
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Welcome and Opening Address - 9th Floor, Lounge
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IFA Leadership
- Peter Connors, President, IFA USA Branch
- Peter A. Glicklich, Executive Vice President
2024 USA Annual Conference Planning Committee
- Candice Turner, Grant Thornton, Regional Vice-President, New York
- Pamela Fuller, Tully & Rinckey, New York Regional Council
- JD Hamilton, Ernst & Young, New York Regional Council
- Michael Miller, Roberts & Holland, New York Regional Council
- Tom Roesser, Microsoft Corporation, New York Regional Council
- Kim Spivey, PwC, New York Regional Council
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9:00 – 10:00 a.m.
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Pillar Two - 9th Floor, Lounge
Sponsored by Tax Analysts
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Moderators:
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Barbara Angus, EY
Cara Griffith, Tax Analysts
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Panelists:
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Mounia Benabdallah, Baker McKenzie
David Lan, KPMG
Jeffrey Mitchell, Senior Adviser, International Co-operation and Tax Administration Centre for Tax Policy and Administration (Invited)
YIN Reporter: Casey Caldwell,
KPMG
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This panel will provide an overview of the current status of Pillar 2. This will include an update on the current status of implementation around the world. The panel will also address the current status of and challenges presented by
the peer review process, recent administrative guidance, and the GloBE information return, safe harbors, and dispute resolution.
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10:00 – 10:30 a.m.
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Refreshment Break - 9th Floor, Card Room
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10:30 – 11:30 a.m.
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Alternative Breakout Sessions
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| International M & A: Current Developments - 10th Floor, Olympic Rooms 1-5 |
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Moderator:
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Candice Turner, Grant Thornton |
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Panelists:
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Kevin M. Jacobs, Alvarez & Marsal Tax
Teisha Ruggiero, Branch Chief at IRS, Office of Chief Counsel (International)(invited)
Moshe Spinowitz, Skadden
Gordon Warnke,
KPMG
YIN Reporter: Emanuel Mkrtchyan, Grant Thornton |
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The International M&A panel will focus on the implications of current developments in international tax on transactions. First, the panel will consider the “Faux CFC” regulations proposed under section 954(c)(6), followed by noted
issues relating to implicit support and AM 2023-008. The panel will also discuss how Rev Proc 2024-1 and Rev Proc 2024-3 have expanded the issues that can be addressed in the Chief Counsel Corporate’s Ruling Program. Next, the panel
will take up how legal entity integration or check-the-box elections impact the availability of foreign tax credits. Finally, the panel will close with a discussion on Pillar 2 UTPR joint venture considerations.
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Where do we stand on OECD's Pillar One - 10th Floor, President Room
Sponsored by Baker Tilly
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| Moderator: |
Joshua Odintz, Holland & Knight |
| Panelists: |
Alexis Bergman, Baker Tilly
Scott Levine, Deputy Assistant Secretary, US Department of Treasury (Invited)
Gary Sprague, Baker McKenzie
YIN Reporter: Marharyta Bahno,
Baker McKenzie |
| This panel will cover the latest Pillar One Developments, including the recent House Ways and Means Committee hearing on Pillar One, the DST definition in the multilateral convention, the Amount B status, and future potential developments.
We will also provide a brief overview of how we arrived at this critical juncture at the Inclusive Framework. |
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11:30 – 12:30 p.m.
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Alternative Breakout Sessions
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| Private Equity - 10th Floor, President Room |
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Moderator:
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Rafael Kariyev, Debevoise |
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Panelists:
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Samuel Duncan, Ropes & Gray
Susanna Parker, Cleary Gottlieb Steen & Hamilton
YIN Reporter: Melanie Xu, Ropes & Gray
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This panel will consider relevant US tax consideration for private equity funds specifically relating to (i) US investors on non-US investments and (ii) non-US investors on US flow through investments.
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| Penalties in International Tax Practice - An Update - 10th Floor, Olympic Rooms 1-5
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| Moderator: |
Melissa Wiley, Lowenstein Sandler |
| Panelists: |
Pedro Corona de la Fuente, Procopio
Megan Brackney, Kostelanetz
Victor Jaramillo, Caplin & Drysdale
Larry Sannicandro, McCarter & English
YIN Reporter: Yelena Niazyan, Kostelanetz |
| Tax controversy professionals - including the current National Taxpayer Advocate - have been bemoaning the complex filing requirements and onerous penalties associated with international information return penalties for years. No longer limited
to the notorious FBAR, the IRS has been cracking down on international information report such as Forms 5471, 5472, 3520, and 3520-A since before the pandemic. As a result, IRS Appeals has seen a deluge of cases challenging international
information return penalties on the grounds of reasonable cause. This past year, it was the courts' turn to chime in. This panel will explore the recent string of international information reporting cases (including Fahry, Aroeste, and
Bittner) and discuss their implications for the future. |
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12:30 – 1:45 p.m.
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Lunch - 11th Floor, Main Dining Room
Sponsored by KPMG
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Government Sit-Down and Fireside Chat
Scott Levine, Deputy Assistant Secretary, US Department of Treasury (Invited)
Interviewers:
Peter Connors, Orrick
Peter Glicklich, Davies Ward Phillips & Vineberg
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1:45 – 2:45 p.m.
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Alternative Breakout Sessions
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The New 987 Regulations - 10th Floor, President Room |
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Moderator:
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Danielle Rolfes, KPMG |
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Panelists:
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Azeka Abramoff, Special Counsel, IRS Associate Chief Counsel (International) (Invited)
Michael Mou, Deloitte
Laura Valestin, PwC
YIN Reporter: Marc Nussbaum,
PwC
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This panel will not provide another overview of the FEEP method included in the 2023 proposed section 987 regulations. Instead, we will focus on four key questions under the proposed regulations:
(1) what happens at transition?
(2) what happens if you terminate a QBU before the rules are finalized?
(3) how should taxpayers think about the various simplifying elections under the proposed regulations; and
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what are some of the remaining pain points (for example, the interaction between 987 and 988)?
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How the UN is Altering the International Tax Landscape - 10th Floor, Olympic Rooms 1-5
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Moderator:
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Patricia Brown, United Nations |
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Panelists:
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Benjamin Angel, Director for Direct Taxation, Tax coordination, Economic Analysis and Evaluation DG TAXUD (European Commission)
Yariv Brauner, University of Florida
Rasmi Das, Chief Commissioner of Income Tax, India
Kehinde Kajesomo, Deputy Director and Head of Treaties and International Tax Policy Division, Federal Inland Revenue Service, Nigeria
YIN Reporter: Logan Kincheloe, Alvarez & Marsal Tax |
| On 22 December 2023, the U.N. General Assembly adopted resolution 78/230, “Promotion of inclusive and effective international tax cooperation at the United Nations.” The resolution establishes an ad hoc inter-governmental committee with a
mandate to develop draft terms of reference for a United Nations framework convention on international tax cooperation. For some tax practitioners, the establishment of the Committee has been unexpected and its possible implications unclear.
The United Nations has, however, provided an alternative approach to international tax rules for decades, an approach that has been followed by many developing countries. This panel will discuss how and why the United Nations’ tax guidance
has increasingly set out a distinctive approach, with a particular focus on how the work of the Committee may affect that trend. |
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2:45 – 3:15 p.m.
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Refreshment Break - 9th Floor, Card Room
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3:15 – 4:15 p.m.
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Alternative Breakout Sessions
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International Aspects of the CAMT - Addressing Open Issues - 10th Floor, President Room
Sponsored by EY
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Moderator:
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Jeshua Wright, EY |
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Panelists:
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Jason Black, PwC
John Franco, Deloitte
Taylor M. Kiessig, Special Counsel, Office of Chief Counsel (International), IRS (invited)
Gary Scanlon, KPMG
YIN
Reporter: Raushan Tumabayeva, PwC |
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This panel will examine recent corporate alternative minimum tax (CAMT) guidance in Notice 2024-10 and Notice 2023-64, including answered and unanswered questions regarding dividends and double counting. This panel will also cover complexities
taxpayers face in applying the CAMT aggregation rules to determine applicable corporation status across various structures, including those with partnerships.
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International Tax Challenges Facing Family Office - 10th Floor, Olympic Rooms 1-5
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Moderator:
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Stanley Ruchelman, Ruchelman PLLC
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Panelists:
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Paul DePasquale, Baker McKenzie
Robert Keller, KPMG
Richard Reinhold, Special Counsel to the ACCI at I.R.S. (Invited)
Emma-Jane Weider, Maurice Turnor Gardner
YIN Reporter: Michael Bennett, Ruchelman PLLC
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| Historically, tax planning and compliance for family offices focused on domestic issues in the home country. But with the internationalization of commerce and international relocation of family members, large family offices now face a new
series of issues at home and abroad. Some are truly domestic issues in the U.S. Others are “domestic” issues that arise in foreign countries for family members residing abroad. Still others are truly international issues encountered as
family offices have expanded investment horizons on a global basis. Drawing upon experience, the panel will discuss hidden tax traps for family members in the U.S. and the U.K. and cross border tax issues commonly associated with multinational
corporations and global investment funds. Cases include (i) Y.A. Global, (ii) Farhy, (iii) Bittner, and (iv) Aroeste. |
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4:15 – 5:15 p.m.
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Alternative Breakout Sessions
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Tax Litigation/Controversy in International Taxation - 10th Floor, President Room
Sponsored by Fenwick
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Moderator:
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Kevin Otero, Covington & Burling |
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Panelists:
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James B. Kelly, Deputy Associate Chief Counsel International (Controversy & Litigation) I.R.S. (Invited)
Sonja Schiller, Alphabet/Google
Julia Ushakova-Stein, Fenwick
YIN Reporter: Tsitsi Mangosho, Covington & Burling |
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This panel will discuss the enforcement environment facing companies, including 1) the types of issues governments are raising in various tax disputes, including the resurgence of the economic substance doctrine, 2) strategies for taxpayers
to implement in response, and 3) best practices for corporate tax teams to pursue to manage the risk and burden of increased scrutiny.
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Crypto Developments: Update on Hot International Tax Topics - 10th Floor, Olympic Room 1-5
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Moderator:
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Sahel Assar, Buchanan Ingersoll & Rooney |
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Panelists:
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Jonathan Cutler, Deloitte
Erika W. Nijenhuis, US Department of Treasury (Invited)
Taylor Reid, Baker McKenzie
Anthony Tuths, KPMG
YIN Reporter:
Matthew Slootsky, Baker McKenzie |
| This panel will explore the federal income tax implications surrounding digital assets, specifically, digital asset reporting, staking, cryptocurrency lending, including safe harbor rules with respect to cryptocurrency trading. |
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5:15 – 6:00 p.m.
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YIN/WIN Cocktail Reception - 9th Floor, Card Room
Sponsored by Davies
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6:00– 7:00 p.m.
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Cocktail Reception - 9th Floor, Card Room
Sponsored by Davies
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7:00 – 9:00 p.m.
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Banquet - 9th Floor, Lounge
Sponsored by Grant Thornton and Loyens
& Loeff
Tickets required
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| Friday March 22 |
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7:30 – 8:30 a.m.
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Breakfast Sessions
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Primer - Update on US International Tax Treaties (YIN Session) - 10th Floor, President
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Moderator:
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Douglas Poms, KPMG |
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Panelists:
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Blake Bitter, Weil
Anna Moss, EY
Jeffrey Tebbs, Miller & Chevalier
Gregory Texley, Senior Technical Reviewer, Branch 1 of the Associate Chief
Counsel Office (International) IRS (invited)
YIN Reporter: Sebastiann Claessen, Loyens & Loeff |
| This panel will provide an update on recent US tax treaty developments, including the recent US-Chile Tax Treaty, the US -Croatia Tax Treaty, a general US tax treaty update, a review of recent cases involving US income tax treaties, and recent
US-Taiwan double tax relief legislation. |
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Unpacking the IRS’ Generic Legal Advice Memorandum (“GLAM”) on Financing Transactions: A Framework for Evaluating the Effects of Implicit Support and Passive Association on the Arm’s-Length Pricing of Intercompany Loans - 10th Floor, Olympic Rooms 1-5
Sponsored by Economics Partners at Ryan
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| Panelists: |
David Suhler, Economics Partners
Brian Vincent, Economics Partners |
| The IRS Office of Chief Counsel recently released a generic legal advice memorandum (“GLAM”), outlining the Agency’s positions with respect to the consideration of group membership and potential implicit support in determining an arm’s-length
rate of interest on intercompany loans. Brian Vincent and David Suhler of Economics Partners at Ryan will discuss pertinent aspects of the GLAM and the Department of Treasury’s Priority Guidance Plan on this topic, while exploring the
economic rationale surrounding implicit support and passive association in the context of the Section 482 guidance on the arm’s-length pricing of intercompany loan transactions, as well as relevant provisions of the OECD’s Transfer Pricing
Guidance on Financial Transactions. |
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8:45 – 9:00 a.m.
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Morning Remarks - 9th Floor, Lounge
IFA Leadership
- Peter Connors, President, IFA USA Branch
- Peter A. Glicklich, Executive Vice President
2024 USA Annual Conference Planning Committee
- Candice Turner, Grant Thornton, Regional Vice-President, New York
- Pamela Fuller, Tully & Rinckey, New York Regional Council
- JD Hamilton, Ernst & Young, New York Regional Council
- Michael Miller, Roberts & Holland, New York Regional Council
- Tom Roesser, Microsoft Corporation, New York Regional Council
- Kim Spivey, PwC, New York Regional Council
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9:00 – 10:00 a.m.
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Corporate International Tax Executives Panel - 9th Floor, Lounge
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Moderator:
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Susan Ludwigson, Morgan Stanley |
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Panelists:
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Aditi Banerjee, Prudential
Carolina Perez Lopez, Johnson & Johnson
Tom Roesser, Microsoft
YIN Reporter: Lisanne Bergwerff, Loyens & Loeff
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10:00 – 10:30 a.m.
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Refreshment Break- 9th Floor, Card Room
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10:30 – 11:30 a.m.
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Alternative Breakout Sessions
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Transfer Pricing Developments - 10th Floor, President Room
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Moderator:
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Steven Wrappe, Grant Thornton |
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Panelists:
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Laurie Dicker, BDO
Rocco Femia, Miller and Chevalier
Sayantani Ghose, KPMG
Ryan Lange, Kroll
YIN Reporter: Natalia Pierotti, Weil, Gotshal
& Manges
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This panel will discuss current U.S. and global transfer pricing trends in examination, litigation, rule changes, penalties, and financial reporting. It will also address the OECD report on Pillar1, Amount B and developments in the Mutual
Agreement Procedure, Advance Pricing Agreement and International Assurance Programs.
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| Partnerships and International Taxation - 9th Floor, Lounge |
| Moderator: |
Seth Green, KPMG |
| Panelists: |
Christopher Bowers, Skadden
Natasha Khemani, Deloitte
Karen Li, Attorney, Office of Chief Counsel (International), IRS (invited)
YIN reporter: Matthew Dimon,
Fenwick
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| This panel will explore the interplay of subchapter K and various international provisions, primarily through the lens of guaranteed payments and preferred returns. |
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11:30 – 12:30 p.m.
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Alternative Breakout Sessions
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| Ethics and Privilege– What’s Trending? - 10th Floor, President Room |
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Moderator:
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Caroline Ciraolo, Kostelanetz |
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Panelists:
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Sharon Katz-Pearlman, Greenberg Traurig
S. Starling Marshall, Crowell Moring
Jeremy Temkin, Morvillo
YIN Reporter: Yelena Niazyan, Kostelanetz
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Legal ethics and the availability and impact of legal privilege is an evolving landscape that requires vigilance by tax practitioners in the United States, as we represent clients (individual or corporate) in cross-border transactions,
whether across state lines or across the oceans. This panel will discuss some emerging trends and critical issues in the world of legal ethics and privilege, and present real-world scenarios demonstrating how to navigate these challenging
and often-turbulent waters.
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Repatriation Planning Panel - 9th Floor, Lounge
Sponsored by EY
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| Moderator: |
Colleen O'Neill, EY |
| Panelists: |
Joseph Calianno, Andersen
Laura Williams, PwC
Brenda Zent, US Department of Treasury (Invited)
YIN Reporter: Raushan Tumabayeva, PwC |
| This panel will be discussing CAMT Notice on distributions, the 961(c) Notice, and the 367(d) proposed regulations. |
| 12:30 – 1:45 p.m. |
Lunch - 11th Floor, Main Dining Room |
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IFA USA Branch Annual General Meeting
Presentation of the IFA USA Writing Prize |
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| 1:45-2:45 p.m. |
Alternative Breakout Sessions
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Recent Foreign Tax Credit Developments - 9th Floor, Lounge
Sponsored by Deloitte
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| Moderator: |
Mallory Mendrala, Deloitte |
| Panelists: |
Rafic Barrage, Baker McKenzie
JD Hamilton, EY
Britt Haxton, KPMG
Hayley Rassuchine, Office of Associate Chief Counsel (International) IRS (Invited)
YIN Reporter: Varuni Balasubramaniam, Baker McKenzie |
| This panel will examine recent foreign tax credit guidance in Notice 2023-55 and Notice 2023-80, including the current state of the creditability rules for foreign taxes and the treatment of certain Pillar Two top-up taxes for U.S. federal
income tax purposes. This panel will also cover various other issues U.S. taxpayers are facing related to Pillar Two top-up taxes and the foreign tax credit. |
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| International Aspects of Crossborder Financing -10th Floor, President Room |
| Moderator: |
John Barlow, Baker McKenzie |
| Panelists: |
Ege Berber, PwC
Lee Holt, EY
Shane McCarrick, Special Counsel, Office of Associate Chief Counsel (International), IRS (invited)
Michiel Schul, Loyens
& Loeff
YIN Reporter: Eric Min, Baker McKenzie |
| This panel will examine new issues that have recently arisen in intercompany financing, in particular with regard to the interaction of Pillar 2, the DCL rules, and the anti-hybrid provisions in Section 267A. The panel may also discuss the
replacement to the funding rule in the final stock buyback regulations and issues that arise from intercompany guarantees. |
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2:45 – 3:00 p.m.
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Refreshment Break - 9th Floor, Card Room
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3:00 – 4:00 p.m.
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More Traps for the Unwary in International Taxation - 9th Floor, Lounge
Sponsored by PwC
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| Moderator: |
Martin Hunter, PwC |
| Panelists: |
Kevin England, DLA Piper
Mark Gasbarra, Forte
Gregory Featherman, Weil, Gotshal & Manges
Prae Kriengwatana,
CBRE
YIN Reporter: Henry Zeng, PwC |
| The panel will address traps for the unwary arising in common practice as well highlight potential missed opportunities in planning and compliance. The subject matter draws primarily on US federal income tax issues arising in both inbound
and outbound practice including issues encountered in the deal setting.” |
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4:00 p.m.
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Concluding Remarks - 9th Floor, Lounge
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