This panel will look at where we are on Pillar 2 as we near the end of the first year of implementation. Panelists will discuss: - How taxpayers are approaching planning and compliance - What we can expect from the Inclusive Framework going forward, and how are countries – including the U.S. – are likely to respond - How taxpayers are dealing with the continued changes in the rules and uncertainty caused by different jurisdictions’ implementation.

Hybrids everywhere! Since the original OECD base erosion and profits shifting project, the OECD and U.S. government have targeted hybrid mismatches. The latest rounds of Pillar Two Administrative Guidance also address additional potential hybrid mismatches. We will explore the development of the various anti-hybrid regimes and discuss traps for the unwary.

Details to come.

On this panel, we will examine the scope and application of anti-abuse rules that frequently arise in cross-border transactions. We will also discuss Treasury's authority to include anti-abuse rules in regulations and IRS enforcement.

Your client failed to report interests in or control over foreign financial accounts, foreign entities, foreign trusts, or gifts from foreign individuals. You know there are several paths to compliance, some much more favorable than others, and your client insists on the broadest protection at the lowest possible cost. This all-to-common scenario presents thorny ethical dilemmas for tax professionals. This panel will walk through the lifecycle of bringing a client with international tax issues into compliance, the ethical issues tax professionals face along the way, the current, relevant authority and guidance, and best practices.

Discussion topics to come.

Discussion topics to come.

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This panel will discuss recent significant cases of note, including Loper Bright, Moore, Liberty Global and the implications of these cases in international tax practice and risk and opportunities presented in the tax controversy landscape facing multinationals.

Topics will potentially include updates related to FTCs, repatriation, treaties, cloud computing, the focus on implicit credit support and intercompany chargeouts, an LB&I download, CAMT, and other pending developments.

Corporate tax insights and pressing issues facing international tax directors

The European Court’s judgment in the Apple/Ireland case will be published on 10th September. This panel will present their initial thoughts about the decision and what it means for the future of taxation and State Aid in the EU.

This panel will discuss certain important worldwide developments, including Australia’s PepsiCo, Inc v Commissioner of Taxation case, withholding tax changes in Australia and the European Union (EU), updates on EU developments (including Public Country by Country Reporting, ATAD III, BEFIT and TP Directive) and domestic developments in select EU jurisdictions.

Panel description to come.

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