Bloomberg BNA

The Tax Policy & Practice Summit

November 13-14, 2012 - The Ritz-Carlton - Washington DC

Educational Course Credit — Up to 15 CPE / CLE Credits Available

Please check back for more details as they become available

Agenda

Keynote Speakers

  • Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation
  • William Wilkins, Chief Counsel, Internal Revenue Service
Schedule

Tuesday, November 13

8:00am – 8:45am Registration and Breakfast

8:45am – 9:00am Opening Remarks
Speakers: Darren McKewen, Vice President & Group Publisher, Bloomberg BNA

9:00am - 10:00am US Information Reporting and Withholding Requirements
Moderator: Kevin Brown, PwC LLP
Speakers: Barry Shott, PwC LLP; Elizabeth Askey, PwC LLP; Scott Dillman, PwC LLP
Sponsored by PwC LLP
This session will focus on the critical need to establish and/or strengthen internal controls to mitigate these risks and costs associated with IRS examinations.

10:00am – 10:15am Refreshments

10:15am – 11:15am Partnerships & Pass-Through Entities
Speaker: Jim Brockway, Withers Bergman LLP; Mitchell Kops, Withers Bergman LLP; Rod Larson, CTC Consulting
Sponsored by Withers Bergman LLP
This policy and practice session will discuss the possible effects of tax reform on pass-through entities using a panel format. It is also intended to provide insight into current and possibly forthcoming developments of importance to practitioners and business and investment managers.

11:15am – 12:15pm The Evolving IRS Enforcement Environment
Speaker: Michael Dolan, KPMG LLP; Sharon Katz-Perlman, KPMG LLP
Sponsored by KPMG LLP
This session will explore how audits, schedule UTP, CAP, and the economic substance doctrine are among the IRS’s most effective enforcement tools.

12:15pm – 2:00pm Keynote Address & Luncheon
Keynote Speaker: Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation
Speaker Introduction: George Farrah, Executive Editor, Bloomberg BNA Tax & Accounting

2:00pm – 3:00pm IRS Administrative Developments in Transfer Pricing That Will Survive Tax Reform
Moderator: Hal Hicks, Skadden
Speakers: Richard McAlonan, Director, Advance Pricing and Mutual Agreement, LB&I, Internal Revenue Service; Robert Green, Skadden; Diane Ryan, Skadden; Tom Horst, Horst Frisch Inc.
Sponsored by Skadden, Arps, Slate, Meagher & Flom LLP
With the push for broad reform of the transfer pricing rules gaining momentum, it remains to be seen how any such reform, such as moving to a territorial taxing regime, would affect dispute resolution mechanisms in the IRS Large Business & International Division that operate based on the current Section 482 regime. This session, which will include current Advance Pricing and Mutual Agreement Program Director Richard McAlonan and former Appeals Chief Diane Ryan, will address how tax reform could affect IRS administrative developments in transfer pricing in LB&I.

3:00pm – 4:00pm Cloud Computing and Other Sales Tax Issues
Moderator: Michele Borens, Sutherland
Speakers: Eric Tresh, Sutherland; Maria Biava, Associate General Counsel, State and Local Tax, Verizon
Sponsored by Sutherland Asbill & Brennan LLP
This session will examine the growing popularity of cloud computing business models that has caught the attention of state tax administrators.

4:00pm – 5:00pm State and Local Business Tax Policy: A Post-Election Roundup
Moderator: Jeff Saviano, Ernst & Young;
Speakers: Joe Crosby, Senior Vice President and Principal, MultiState Associates; Bob Cline, Ernst & Young; Steven N.J. Wlodychak, Ernst & Young LLP
Sponsored by Ernst & Young LLP
Fresh on the heels of the outcome of the November election, this panel will offer its insight on what the electoral results mean for state and local business taxes, and identify those crucial economic, legislative, regulatory, and judicial trends that will shape the future of the state taxation of businesses.

5:00pm Reception

Wednesday, November 14

7:00am – 8:00am Breakfast

8:00am – 9:00am Federal Tax Update: The Current Situation and the Prospects for Reform
Speaker: Hank Gutman, KPMG
Sponsored by KPMG LLP
This session will focus on ways for corporate tax teams to obtain the latest information they need to understand and digest tax reform proposals, pool ideas, and present a united front.

9:00am – 10:00am Recent Developments and Policy Issues in Cross-Border Taxation
Moderator: Chris Bowers, Bingham McCutchen LLP
Speakers: Ronald Dabrowski, Deputy Associate Chief Counsel (International - Technical), Internal Revenue Service; Patrick Brown, Senior International Tax Counsel, General Electric Company
Sponsored by Bingham McCutchen LLP
This panel will examine recent developments in international and cross-border tax issues.

10:00am – 10:15am Refreshments

10:15am – 11:15am The Affordable Care Act: The Road Forward for Employers
Speakers: Alden J. Bianchi, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo P.C.; Tammy E. Pitts, Associate General Counsel, Citigroup Inc.
Sponsored by Mintz, Levin, Cohn, Ferris, Glovsky and Popeo P.C.
The speakers will discuss strategies for managing the fast approaching deadlines and challenges employers are facing due to the Patient Protection and Affordable Care Act.

11:15am – 12:15pm Current Tax Issues with Respect to International Treasury Operations
Moderator: L.G. “Chip” Harter, PwC LLP
Speakers: Jeffrey Maddrey, PwC LLP; David Shapiro, PwC LLP; Jeff Dorfman, PwC LLP
Sponsored by PwC LLP
This session will review ways in which multinational corporations are attempting to manage currency risk as well as recent experience with IRS examinations of such techniques.

12:15pm – 1:15pm Keynote Address & Luncheon
William Wilkins, Chief Counsel, Internal Revenue Service
Speaker Introduction: Leonard L. Silverstein, Chair, Bloomberg BNA Tax & Accounting Advisory Boards; Shareholder, Buchanan Ingersoll & Rooney PC

1:15pm – 2:15pm Financial Reporting for Income Taxes
Speaker: Patrick Trapp, Ernst & Young LLP; David Northcut, Ernst & Young LLP; Michael H. Salama, Vice President Corporate Tax and Senior Tax Counsel, Disney Corporation
Sponsored by Ernst & Young LLP
This practice-oriented session addresses the rapidly growing challenges and uncertainties that corporations face in their tax accounting processes.

2:15pm – 3:15pm Reporters Roundtable
Moderator: Karen Fickes, Bloomberg BNA
Speakers: Brett Ferguson, Bloomberg BNA; Richard Rubin, Bloomberg L.P.; Heather Rothman, Bloomberg BNA

3:15pm – 4:15pm The Road to Corporate Tax Reform
Moderator: Clark Hoyt, Bloomberg News
Speakers: Elaine Kamarck, RATE Co-Chair; James Pinkerton, RATE Co-Chair; Michael D. Fryt, Corporate Vice President, Tax, FedEx Corporation; Anne Buettner, Senior Vice President, Tax, Walt Disney; Diane Dossin, Ford Motor Company
Co-chairs of RATE (Reforming America's Taxes Equitably) will explain the process for accomplishing tax reform and how it will make our economy globally competitive again.

*Refreshments will be available all afternoon in the back of the room- no formal break