Mike Silva and John Lutz spoke on this panel which focused on a deep dive into final and proposed section 163(j) regulations and their impact on financing for inbound companies.
Hot Topics in State & Local Tax
During this session, Steve Kranz and Katie Quinn discussed current state controversy issues, the tax implications of COVID-19 on state fiscal health and the expected responses leading into 2021.
Potential Legislative & Regulatory Impact of the U.S. 2020 Election
Dave Noren and Mike Bruno spoke at this session which focused on the outlook for tax legislation and regulatory guidance under either a new Biden administration or a second term for President Trump. Also discussed was the likely substance and timing of various potential policy changes important to US inbound multinational operations, as well as planning measures that taxpayers may consider taking at a time of considerable policy uncertainty.
Global Tax Policy Update: Digital Services Taxes & the OECD
Speakers Brian Jenn and Antoine Vergnat covered the latest developments related to OECD Pillars One and Two, as well as recent individual country measures, including new digital services taxes and potential meshing of US and other individual country regimes with Pillar One and Two principles.
Related Party Financing of US Operations
Caroline Ngo and Jonathan Lockhart covered the latest developments affecting internal financing of US operations during this session, including the final Section 267A regulations and the status of Section 385 regulations.
US Tax Controversy Update
Andy Roberson and Kevin Spencer discussed recent and pending tax and transfer pricing cases relevant for inbound companies along with recent audit trends during this panel.
Planning for Higher International Tax Rates: Outlook for Tax Changes Around the World & How to Plan Now
Around the world, tax rates are poised to increase. Speakers Manuel Rajunov and Steve Hadjilogiou explored what the outlooks are for tax rate changes around the world, and what taxpayers can do now to plan for potential changes. This session focussed on how to utilize traditional IT planning techniques for IP and financing in the current and expected future environment.
Hot Topics in M&A Transactions
During this session, Tim Shuman and Britt Haxton provided an update on Section 245a regulations and discussed a variety of practical considerations and technical issues related to post-tax reform M&A deals, including BEAT aggregation rules when combining groups, due diligence considerations, post-merger realignment and integration and other planning opportunities.