Sep 23
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08:30 - 08:55 25 mins
Registration & Coffee
08:55 - 09:00 5 mins
Opening remarks from the chairperson
  • Ben Jones - Partner, EVERSHEDS SUTHERLAND
09:00 - 09:25 25 mins
The U.S. Tax Reform 1 year on: key changes and points of contention
09:25 - 09:50 25 mins
Structuring to Address the Base Erosion and Anti-Abuse Tax

This session will address practical considerations with respect to the application of the section 59A Base Erosion Anti-Abuse Tax, focusing particularly on issues addressed in the proposed and possibly final regulations.  The discussion will include practical considerations, including multiple-party contracting approaches, the implications of general U.S. federal income tax principles on the determination of whether payments are “base erosion payments,” the application of anti-abuse rules, and practical considerations to address the potential application of the section 59A anti-abuse tax to U.S. taxpayers.

  • Clark Armitage - Member, CAPLIN & DRYSDALE
  • Liz Stevens - Associate, CAPLIN & DRYSDALE
09:50 - 10:40 50 mins
Finding Foreign Derived Intangible Income Under the Proposed Regulations (Panel)

Section 250, which provides deductions for GILTI and FDII, was intended to make U.S. taxpayer’s neutral as to whether foreign derived intangible income is earned in the U.S. or outside the U.S.  Proposed regulations under section 250 provide detailed information and documentation rules for purposes of determining a taxpayer’s foreign derived intangible income.  This session will discuss the requirements of the proposed regulations and will explore, through case studies, the practical application of the proposed regulations, focusing on the different requirements for various sales and services transactions.

  • Moderator Liz Stevens - Associate, CAPLIN & DRYSDALE
10:40 - 11:00 20 mins
Coffee break
11:00 - 11:50 50 mins
Living in a Digital World: The Implications of Digital Tax Proposals on U.S.

This session will explore the current proposals targeted at addressing digital businesses, focusing on the implications for U.S. multinationals and companies with activities in the United States.  We will explore the approaches under consideration by the OECD, the EU and individual jurisdictions, including digital services taxes, changes to taxable presence standards in the U.S. under Wayfair and in non-US jurisdictions, implications for transfer pricing and particularly the value of marketing intangibles, and the role of minimum tax regimes, such as the U.S. GILTI regime in addressing the concerns raised by the taxation of digital businesses.

  • Maria Todorova - Partner, EVERSHEDS SUTHERLAND
11:50 - 12:40 50 mins
Impact of U.S. tax reform on transfer pricing – The industry view
  •  International tax provisions most affecting transfer pricing
  • Rethinking existing structures
  •  Potential TP controversy arising from U.S. tax reform
  •  Risk mitigation strategies
  • Moderator Victor Miesel - Principal, Chief Economist and Practice Leader, Transfer Pricing and Economics Group, MAZARS
  • Kate Bushby - International Tax, TRANSFERWISE
  • Clark Armitage - Member, CAPLIN & DRYSDALE
  • Noah Gaoua - Head of Group Tax, NOVARES
  • Lee Holloway - Head of Tax and Pensions, NEXT PLC
12:40 - 13:05 25 mins
Managing International Tax Audit and Controversy in the Information Age

Increased access to information has changed the way that tax authorities approach taxpayer audit’s and controversies, including in the United States where new guidelines provide for the use of information technology to identify issues for large corporate audits.  The new information reporting requirements in the EU (DAC 6) and elsewhere, increases the information that is potentially available to revenue authorities when auditing multinational taxpayers.  This session will discuss recent developments in audit and controversy, including the implications of new information reporting rules, taxpayer rights with respect to the sharing of information, OECD coordinated audits, and practical considerations for companies in managing audit and controversy risk.  

  • Maria Todorova - Partner, EVERSHEDS SUTHERLAND
13:05 - 14:05 60 mins
Networking Lunch
14:05 - 14:30 25 mins
The Implications of International Tax Reform on Check the Box and Hybrid Planning Structures

The entity classification rules, and particularly the check-the-box rules, historically have provided U.S. taxpayers with significant flexibility in domestic and international tax planning.  This discussion will address how U.S. and non-U.S. tax reforms are affecting the use of disregarded entities and transactions, focusing particularly on the section 267A anti-hybrid rules, the corollary in section 245(e), the implications of the new foreign branch foreign tax credit basket, dual consolidated loss considerations and the operation of the FDII rules in relation to foreign branch activities.  

  • Howard Wiener - Principal, U.S. Tax Practice in Europe, London, KPMG LLP (U.S.)
14:30 - 15:20 50 mins
In conversation with the U.S. Treasury – Keynote session
  • Douglas Poms - International Tax Counsel (Invited), U.S. Treasury
  • Moderator Jonathan Horn - Senior Manager – AICPA Tax Policy & Advocacy, AICPA
15:20 - 16:10 50 mins
Rethinking the Deal: Case Studies in M&A Post-Tax Reform

This session will explore, through case studies the new considerations that are relevant to U.S. multinationals in acquisition, disposition and integration transactions.  We will explore the implications of tax reform on traditional section 338(g) and check-and-sell structures, as well as taxable asset and stock purchases and tax-free reorganizations.  The focus of this panel discussion will be on transactions that are being considered to specifically address changes made as part of U.S. tax reform.

  • Maria Todorova - Partner, EVERSHEDS SUTHERLAND
16:10 - 16:30 20 mins
Afternoon coffee break
16:30 - 16:55 25 mins
Technology Solutions for Tax Reform Compliance
  • Mark Friedlich - Senior Principal, Tax & Accounting North America, WOLTERS KLUWER
16:55 - 17:45 50 mins
How multinationals are affected by changes/implications for cross-border business?
  • Marjane Lagha - EMEA Tax Advisor, OMNICOM GROUP
  • David Domizioli - Tax Director, DOLCE & GABBANA S.r.l
  • Clive Baxter - Head of Tax Governance and Policy, MAERSK
  • Moderator Jon Lamphier - Managing Director, Vistra US Tax, Accounting, and Corporate Legal Solutions, VISTRA
17:45 - 17:50 5 mins
Closing Remarks and Drinks Reception
  • Ben Jones - Partner, EVERSHEDS SUTHERLAND