Tuesday, November 13
8:00am – 9:00am Registration and Breakfast9:00am - 10:00am US Information Reporting and Withholding RequirementsModerator: Kevin Brown, PwC LLPSpeakers: Linda Stiff, PwC LLP; Barry Shott, PwC LLP; Michael Plowgian, Attorney Advisor, Office of International Tax Counsel, US Department of the TreasurySponsored by PwC LLPThis 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 Refreshments10:15am – 11:15am Partnerships & Pass-Through EntitiesSpeaker: Jim Brockway, Withers Bergman LLP; Mitchell Kops, Withers Bergman LLPSponsored by Withers Bergman LLPThis 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 EnvironmentSpeaker: Michael Dolan, KPMG LLP; Sharon Katz-Perlman, KPMG LLPSponsored by KPMG LLPThis 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 & LuncheonKeynote Speaker: Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation2:00pm – 3:00pm IRS Administrative Developments in Transfer Pricing That Will Survive Tax ReformModerator: Hall Hicks, SkaddenSpeakers: 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 IssuesModerator: Michele Borens, SutherlandSpeakers: Eric Tresh, Sutherland; Maria Biava, Associate General Counsel, State and Local Tax, VerizonSponsored by Sutherland Asbill & Brennan LLPThis 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 RoundupModerator: Jeff Saviano, Ernst & YoungSpeakers: Joe Crosby, Senior Vice President and Principal, MultiState Associates; Bob Cline, Ernst & Young; Steven N.J. Wlodychak, Ernst & Young LLPSponsored by Ernst & Young LLPFresh 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 ReceptionWednesday, November 147:00am – 8:00am Breakfast8:00am – 9:00am Planning For & Shaping Corporate Tax ReformSpeaker: Hank Gutman, KPMGSponsored by KPMG LLPThis 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 TaxationModerator: Chris Bowers, Bingham McCutchen LLPSpeakers: Ronald Dabrowski, Deputy Associate Chief Counsel (International - Technical), Internal Revenue Service; Patrick Brown, Senior International Tax Counsel, General Electric CompanySponsored by Bingham McCutchen LLPThis panel will examine recent developments in international and cross-border tax issues.10:00am – 10:15am Refreshments10:15am – 11:15am The Affordable Care Act: The Road Forward for EmployersSpeakers: 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 OperationsModerator: L.G. “Chip” Harter, PwC LLPSpeakers: Jeffrey Maddrey, PwC LLP; David Shapiro, PwC LLP; Jeff Dorfman, Office of Chief Counsel, Internal Revenue Service;Sponsored by PwC LLPThis 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 & LuncheonWilliam Wilkins, Chief Counsel, Internal Revenue Service1:15pm – 2:15pm Financial Reporting for Income TaxesSpeakers: Angela Evans, Ernst & Young LLP; Michael H. Salama, Vice President Corporate Tax and Senior Tax Counsel, Disney Corporation; Patrick Trapp, Ernst & Young LLPThis practice-oriented session addresses the rapidly growing challenges and uncertainties that corporations face in their tax accounting processes.2:15pm – 3:15pm Reporters RoundtableModerator: Karen Fickes, Bloomberg BNASpeakers: Brett Ferguson, Bloomberg BNA; Richard Rubin, Bloomberg L.P.; Heather Rothman, Bloomberg BNA3:15pm – 4:15pm The Road to Corporate Tax ReformModerator: Clark Hoyt, Bloomberg NewsSpeakers: Elaine Kamarck, RATE Co-Chair; James Pinkerton, RATE Co-Chair; Add Diane Dossin, Ford Motor CompanyCo-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.
Ernst & Young
KPMG LLP, the audit, tax and advisory firm, is the U.S. member firm of KPMG International Cooperative ("KPMG International"). KPMG International’s member firms have 145,000 professionals, including more than 8,000 partners, in 152 countries.KPMG delivers a globally consistent set of multidisciplinary services based on deep industry knowledge. Our industry focus helps KPMG professionals develop a rich understanding of clients' businesses and the insight, skills, and resources required to address industry-specific issues and opportunities.Our history spans three centuries and features a number of significant mergers, most recently the combination of Peat Marwick International and Klynveld Main Goerdeler, and their individual member firms, into KPMG in 1987.
Bingham McCutchen LLP
Mintz Levin Cohn Ferris Glovsky and Popeo PC
Founded in 1933, Mintz Levin has grown into a versatile law firm of 500 highly qualified and dedicated attorneys representing diverse international clients in many industries who turn to us for a wide range of legal services and resources. Our offices are located in Boston, Washington, D.C., New York, San Diego, Los Angeles, San Francisco, Stamford (CT), and London.
Skadden, Arps, Slate, Meagher & Flom LLP & Affiliates
With approximately 1,800 attorneys in 23 offices on five continents, Skadden, Arps, Slate, Meagher & Flom LLP and affiliates (“Skadden”) serves clients in every major financial center. Its strategically positioned U.S. and international locations allow proximity to clients and their operations and ensure a seamless and unified approach at all times. For more than 60 years, Skadden has provided legal services to the corporate, industrial, financial and governmental communities around the world in a wide range of high-profile transactions, regulatory matters, and litigation and controversy issues. Clients range from a variety of small, startup companies to a substantial number of the 500 largest U.S. corporations and many of the leading global companies. The firm has represented numerous governments, many of the largest banks — including virtually all of the leading investment banks — and major insurance and financial services companies. Skadden has more than 40 practice areas and advises clients in matters involving, among others, tax, mergers and acquisitions, litigation and arbitration, corporate finance, corporate restructuring, securities law, banking, project finance, energy, antitrust and intellectual property.
Sutherland Asbill & Brennan LLP
Sutherland Asbill & Brennan LLP is a law firm known for solving challenging business problems and resolving sophisticated legal issues for many of the world’s largest companies. Founded in 1924, the firm handles matters throughout the United States and worldwide. Seven major practice areas—corporate, energy and environmental, financial services, intellectual property, litigation, real estate, and tax—provide the framework for an extensive range of focus areas, allowing Sutherland attorneys to serve a diverse client base that ranges from small and medium-sized start-up businesses to a significant number of Fortune 100 companies. Sutherland SALT is one of the premier state and local tax law practices in the country, with 29 lawyers representing more than 25 of the Fortune 100 and numerous other clients that are recognized leaders in their respective sectors.
Withers Bergman LLP
Withers Bergman LLP is an international law firm dedicated to the personal, business and philanthropic interests of successful individuals, their families and advisers. It has over 250 attorneys worldwide who have experience in tax, trust and estate planning, as well as commercial, litigation, employment and other legal issues facing our clients.