In this session Michael Bruno, David Noren will provide up to the minute insights on the current tax reform process making its way through Congress. We will focus on key provisions impacting international companies, such as SHIELD, BEAT, interest limitations, anti-inversion rules, and for those with sandwich structures, GILTI and subpart F changes. In addition, we will discuss the legislative process and prospects for passage.
Policies, Penalties & Predictions: State Tax Issues for Multinationals
In this session Steve Kranz, Diann Smith will states continue to address complex federal tax changes, misperceived tax fairness issues, and asserted revenue needs using inconsistent and inappropriate methods. This session will discuss novel theories used by the states to raise additional revenue and to punish disfavored taxpayers. The conversation will also address issues related to state conformity with proposed federal reforms; trends in new taxes targeting specific industries and taxpayers; and tax haven, combined reporting, and intercompany pricing developments. Finally, the session will provide predictions on where new state tax issues are likely to arise in the context of international discussions surrounding theories such as a global minimum tax.
Recent Inbound Financing Developments
Caroline Ngo, Jonathan Lockhart will be panelists which will address planning considerations under Section 267A and revised Section 163(j). We will also consider the prospects for another legislative attempt to enact previously proposed Section 163(n) (limiting interest deductibility based on a US/OUS “excess indebtedness” determination), how the provision might work in tandem with the other international tax changes being proposed, and how inbounds should think about their relative mix of intra-group and third-party debt in light of the evolving landscape in this area.
US Tax Controversy Update: Managing Audits as an Inbound Taxpayer
Kevin Spencer, Jenny Johnson Ware will be panelists which will discuss recent experience with IRS challenges of intercompany interest expense and services charge-outs, trade-offs of being in or out of CAP from an inbound company’s perspective, and other controversy issues.
IP & Supply Chain Planning
In this sessionSteven Hadjilogiou, Elizabeth Lu will discuss the global landscape is changing. FDII incentivizes companies to retain US ownership of IP. With the potential elimination of the regime, or a reduction in benefits, is it time to consider centralizing IP ownership elsewhere? This session will focus on the latest trends in IP and supply chain planning. This panel also will address planning in an environment of FDII uncertainty both in the transition phase and in a steady state post-implementation of new rules.
Planning in an environment of FDII uncertainty – this panel will address potential FDII repeal or overhaul scenarios, and consider planning considerations for inbound companies under these scenarios, both in a transition phase (e.g., prepayments and other transition planning) and in a steady state post-implementation.
Global Tax Policy Update
Brian Jenn, Meaghan Wolfe will be panelists which will cover the latest developments on the OECD’s Pillar One and Pillar Two, as well as recent individual country measures, such as new digital services taxes and potential meshing of U.S. and other individual country regimes with Pillar One and Pillar Two principles.
Hot Topics in Transfer Pricing
Michael Hardgrove, Andrew Roberson will cover the practical impact of Pillar One, an overview of transfer pricing issues to be addressed in the U.S. Treasury Department’s Priority Guidance Plan, current planning strategies in transfer pricing, and updates on APAs, MAP and current litigation.
Year End Planning for Tax Reform
Manuel Rajunov, Britt Haxton discuss the prospect for higher corporate tax rates, the elimination or modification of FDII, increased interest limitations, and many other changes, this session will cover year-end planning transactions. We will discuss any limitations on accounting method changes and key effective date provisions in the tax reform bills as well as permissible transactions to take advantage of the current tax rules.
Proliferation of Digital Assets
Andrea Kramer, Carlos Ortiz discuss Satoshi Nakamoto published Bitcoin white paper. This sparked transformative impact to investing, financial products, and broader financial services. Today, we are living an evolution of commerce influenced by blockchain and digital assets hitting every industry in every geography. Crypto is increasingly a part of major brands and yet, the regulatory environment continues to be dynamic with relatively few tax rules on point. In this panel, you will hear from Deloitte & McDermott’s leaders in this field who will provide an overview of the current state of the industry, explain the tax complexities associated with crypto as well as corresponding enforcement efforts in this globally connected ecosystem.
Hot Topics in M&A
In this session Jeffrey Maydew, Timothy Shuman will focus on current issues in inbound M&A and post-merger integration, including out-from-under transactions and disposition planning. We will also discuss provisions of tax reform that may impact the M&A such as proposed anti-inversion rules and the proposed retroactive changes to Section 245A regarding extraordinary disposition transactions.