2010 Conference Technical Program
The Technical Program will consist of 2 days of panel sessions, Thursday February 25 and Friday February 26, 2009.
| Thursday, February 25, 2010 | |||
| 7:30 a.m. | Registration opens, Morning refreshments | ||
| 8:30 - 8:45 a.m. |
Welcome Remarks | ||
| Joan C. Arnold, Pepper Hamilton LLP, Chair of the IFA USA Branch 2010 Annual Conference | |||
| Brainard L. (Skip) Patton, President IFA USA Branch | |||
| 8:45 - 10:15 a.m. |
Planning for Outbound Structures Under the Proposed Legislation | ||
| Being proactive – this panel will explore restructuring options, both operation and structural, that companies are considering to plan for the proposed legislation. | |||
| Chair: | Eric Solomon, Ernst & Young LLP | ||
| Panelists: | Philip R. West, Steptoe & Johnson LLP | ||
| Manal S. Corwin, International Tax Counsel, Department of the Treasury | |||
| Patrick Brown, General Electric Company | |||
| 10:15 - 10:45 a.m. |
Refreshment Break | ||
| 10:45 - 12:00 p.m. |
What is it You are Paying? | ||
| Characterizing payments is crucial for sourcing and withholding. The panelists will discuss current issues in characterizing payments made in the ordinary course of business and in financial transactions. | |||
| Chair: | William S. Dixon, Citigroup Inc. | ||
| Panelists: | David H. Shapiro, PricewaterhouseCoopers LLP | ||
| Michael A. DiFronzo, Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service | |||
| 12:00 – 1:30 p.m. |
Lunch | ||
| Speaker: Stephen E. Shay, Deputy Assistant Secretary for International Tax Affairs, Department of the Treasury | |||
| 1:30 - 2:45 p.m. |
Current and Future Withholding Tax Issues | ||
| This is not just for QIs – the current withholding tax rules and the proposed withholding tax rules are a key issue for US companies. It is a Tier 1 audit issue, and if the proposed legislation is passed, there is an entire new chapter of the Code to plan for! | |||
| Chair: | John M. Staples, Burt, Staples & Maner, LLP | ||
| Panelists: | Jake Braun, JPMorgan Chase & Co. | ||
| Edward Tanenbaum, Alston & Bird LLP | |||
| Steven A. Musher, Associate Chief Counsel (International), Internal Revenue Service | |||
| 2:45 - 3:15 p.m. |
Refreshment Break | ||
| 3:15 - 4:15 p.m. |
Working with Supply Chain Changes | ||
| What’s working, what’s not, both abroad and in the US. A review of specific case studies of what is being planned and implemented, and the challenges that are being faced. | |||
| Chair: | Thomas M. Zollo, KPMG LLP | ||
| Panelists: | Jim Allie, DuPont | ||
| Scott Gregg, Ashland | |||
| Itai Grinberg, Attorney Advisor, Office of Tax Policy, Department of Treasury | |||
| 4:15 - 5:30 p.m. |
Have You Thought About State Taxes Lately? | ||
| This panel focuses on cutting edge state tax issues for US outbound and inbound multinationals. It will address topics such as including foreign entities in combined reporting, treatment of Subpart F income, the growing focus on nexus, allocating state taxes in foreing tax credit planning. | |||
| Chair: | Peter A. Barnes, General Electric Company | ||
| Panelists: | Alan Pasetsky, Nestle | ||
| David Hartley, AHold | |||
| 6:30 - 10:00 p.m. |
Reception and Banquet | ||
|
Friday, February 26, 2010 | |||
| 7:30 a.m. |
Morning refreshments | ||
| 8:45 - 10:15 a.m. |
Current Topics in Section 956 – Pushing the Envelope and Planning | ||
| What are lenders requesting and how are borrowers responding? What internal transactions are creating exposure? What planning is occurring in transactions to permit continued deferral of income? | |||
| Chair: | Kimberly S. Blanchard, Weil, Gotshal & Manges, LLP | ||
| Panelists: | Scott M. Dayan, Kilpatrick Stockton LLP | ||
| Lewis Steinberg, UBS | |||
| Government Person TBD | |||
| 10:15 - 10:45 a.m. |
Refreshment Break | ||
| 10:45 - 12:00 a.m. |
Managing the International Aspects of an Audit and FBAR Issues for Corporations | ||
| With the increased focus of the IRS on enforcement in the international area, and the devotion of resources to the area, companies need to pay additional attention to the management of the international aspects of the audit. This panel will address the IRS’ approach to international audits and enforcement, and practical issues in managing such audits. It will also address FBAR compliance issues for corporations. | |||
| Chair: | Gerald A. Kafka, Lathan & Watkins LLP | ||
| Panelists: | Kurt Meier, Deputy Chief of Appeals, Internal Revenue Service | ||
| Bettie Ricca, Deputy Associate Chief Counsel (International), Internal Revenue Service | |||
| Kathy Petronchak, Deloitte Tax LLP | |||
| 12:00 - 1:30 p.m. |
Lunch | ||
| USA Branch General Meeting Brainard L. (Skip) Patton, President IFA USA Branch, Presiding 2009 IFA USA Branch Writing Prize Presentation 2010 Congress National Reporter comments | |||
| 1:45 - 3:00 p.m. |
Transfer Pricing – Managing the Issues in a Changed Economy | ||
| How have practices changed, what do you do about your comparables, and in other items of change. | |||
| Chair: | Alan Shapiro, Deloitte Tax LLP | ||
| Panelists: | David Wallenstein, Tyco | ||
| Steven A. Musher, Associate Chief Counsel (International), Internal Revenue Service | |||
| 3:00 - 4:00 p.m. |
Selected Current Developments | ||
| Chair: | James P. Fuller, Fenwick & West LLP | ||
| Panelists: | Larissa Neumann, Fenwick & West LLP | ||
| Rogers Drew, Procter & Gamble | |||
| Suchi Lee, PricewaterhouseCoopers LLP | |||
| 4:00 p.m. | End of conference | ||
2/17/10 12:27 PM