Peter Glicklich, Davies Ward Phillips & Vineberg

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.

Moderator:
Michael Plowgian, KPMG

Speakers:
Jeff Mitchell, Senior Advisor, OECD
Colleen O'Neill, EY
Bob Stack, Deloitte
Isaac Wood, Office of Tax Policy, U.S. Department of the Treasury (invited)

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.

Moderator:
Joshua Odintz, Holland & Knight

Speakers:
Aaron Junge, PwC
John Merrick, IRS - Office of Chief Counsel
Julia Skubis-Weber, Baker McKenzie

Aharon J. Friedman, Federal Policy Group
Joshua Odintz, Holland & Knight.

Moderators:
Peter Glicklich, President, IFA USA Branch – Davies Ward Phillips & Vineberg, New York
Dirk Suringa, Vice President, IFA USA Branch - Covington & Burling

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.

Moderator:
Laura Williams, PwC

Speakers:
Jenny Austin, Mayer Brown
David Berke, Special Counsel, Office of Associate Chief Counsel (invited)
Jose Murillo, EY
YIN Reporter: Aaron Ma, PwC

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.

Moderator:
Caroline Ciraolo, Kostelanetz

Speakers:
Rochelle Hodes, Crowe
Gwen Moore, Moore Tax Law (Chicago)
Christopher Rizek, Holland & Knight

In this event, our WIN leaders will facilitate an open discussion on compliance issues related to Form 1118 and other FTC developments.

Moderator:
Neelu Mehrotra, EY - WIN Chair

Committee members:
Liliana Galindo, Ryan
Brooke Bodziner, Eisner Advisory Group

Peter Glicklich, Davies Ward Phillips & Vineberg

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.

Moderator:
Michael Caballero, Covington & Burling

Speakers:
Bill Curran, Davis Polk
James Kelly, Deputy Associate Chief Counsel, International (Controversy & Litigation) · IRS, Office of Chief Counsel
Saul Mezei, Gibson Dunn
YIN Reporter - Jesse Boretsky

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.

Moderator:
Danielle Rolfes, KPMG

Speakers:
Loren Ponds, Miller & Chevalier
Larissa Neuman, Fenwick & West
Paul McLaughlin, Special Counsel in the IRS Office of the Associate Chief Counsel (International) (invited)

Moderator:
Catherine Schultz, Business Roundtable

Speakers:
Ross Kearney, RTX
Alyson Lawrence, Johnson & Johnson
Tom Roesser, Microsoft

The European Court's judgement in the Apple/Ireland case will be published on September 10th. 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.

Moderator:
Liesl Fichardt, Quinn Emmanuel

Speakers:
Dr. Stephen Daley, King’s College London
Prof. Sjoerd Douma, University of Amsterdam
Ruth Mason, University of Virginia
Conor Quigley KC, Serle Court Chambers, UK

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.

Moderator:
Alfonso Dulcey, Weil, Gotshal & Manges

Speakers:
Amie Colwell Breslow, Jones Day
Brian Doohan, Matheson
Stuart Landsberg, PwC (Australia)
Michiel Schul, Loyens & Loeff
YIN Reporter - Laurens Hoek, Loyens & Loeff

Panel description to come.

Moderator: Pat Brown, PwC

Speakers:
Audrey Charling, GE
Mark Gasbarra, Forte
Eric Sloan, Gibson Dunn
Amanda Varma, Steptoe & Johnson