DAY 1: WEDNESDAY, JUNE 8, 2016

8:00 am - 9:00 am          Registration and Breakfast


9:00 am – 9:45 am         Keynote Address

Mike Williams, Director of Business and International Tax, HM Treasury

9:45 am – 10:45 am      Rewarding Risks and Intangibles—Including Hard-to-Value Intangibles--Under New OECD and U.S. Approaches
The OECD’s BEPS guidance on rewarding risk from intangibles, especially those that are hard to value, focuses on “DEMPE” functions--development, enhancement, maintenance, protection and exploitation. At the same time, the IRS has proposed rules requiring compensation for an outbound transfer of foreign goodwill and going concern value. In addition, in May this year, the OECD is expected to issue a draft and hold a consultation regarding additional guidance around “hard to value intangibles.” What are the common elements to these changes—and how, and to what extent, will they affect company structures and intangibles transfers going forward?

Moderator: John M. Peterson, Jr., Partner, Baker & McKenzie, Palo Alto
Christopher Bello, Chief, Branch 6, Office of the Associate Chief Counsel (International), IRS
Brian A. Cromwell, Principal Economist, Baker & McKenzie Consulting, LLC, Palo Alto
William J. Sample, Corporate Vice President - Worldwide Tax, Microsoft Corporation


10:45 am – 11:00 am     Refreshment Break

11:00 am – 12:00 pm     Documentation and Country-by-Country Reporting
Country-by-country reporting has been called the BEPS project’s greatest legacy, and this recommendation is likely causing more compliance work for taxpayers than any other. Corporate and government panelists will discuss the exercise of complying with new requirements, in particular the challenges caused by the mismatch between the effective dates for U.S. and non-U.S. jurisdictions, sourcing the information, and the need for a consistent approach to transfer pricing across the entire supply chain.

Moderator: Molly Moses, Managing Editor, think and code
Philip W. Carmichael, Principal Economist, Baker & McKenzie Consulting, LLC, New York
John Hickey, Director, Global Transfer Pricing, Johnson & Johnson
Brian Jenn, Attorney-Advisor, Office of International Tax Counsel, US Treasury
Sharon Porter,  Director, Treaty and Transfer Pricing Operations, IRS
Oginan Stoichkov
, Director, Global Transfer Pricing, PepsiCo, Inc.


12:00 pm – 1:00 pm       Luncheon

1:00 pm – 1:30 pm         Keynote Address

Theodore Setzer, Assistant Deputy Commissioner - International, IRS

1:30 pm – 2:45 pm        Resolving Cross-Border Cases in a Post-BEPS World
Double-tax disputes are on the rise, and likely to increase further with BEPS-driven changes.  As more taxpayers look to Competent Authority, APAs, and other mechanisms to obtain certainty, countries are struggling to keep up with demand.  This session will explore the current state of case resolution in key jurisdictions and provide practical insights on what taxpayers can realistically expect to achieve in the process.   

Moderator: Carol A. Dunahoo, Partner, Baker & McKenzie, Washington, DC
Donna McComber, Assistant Director, Advance Pricing and Mutual Agreement Program, IRS
John Hughes,  Senior Advisor – Transfer Pricing Operations, IRS
Sanjiv Malhotra, Director of Economics, Baker & McKenzie Consulting, Pte. Ltd., Singapore
Paul Morton, Head of Group Tax, RELX Group plc
Carlos Pérez Gómez Serrano, Director of Transfer Pricing Audits, Mexican Tax Administration Service (SAT)
Shanwu Yuan, International Tax Director, Baker & McKenzie Consulting, LLC, New York and Shanghai


2:45 pm – 3:00 pm         Refreshment Break

3:00 pm – 4:00 pm         Issues in Pending Transfer Pricing Court Cases and Their Implications
Transfer pricing litigation has burgeoned in recent years, with court challenges to IRS allocations from buy-in payments and other intangibles transfers, licensing, Section 936 exit strategies and foreign blocking laws. What do these cases reveal about the IRS’s audit and litigation strategy? 

Moderator: Thomas V. Linguanti, Partner, Baker & McKenzie, Chicago
Saul Mezei, Partner, Morgan, Lewis & Bockius LLP
Holly McClellan, Director, Global Transfer Pricing, Tax Counsel, General Electric
Andrew P. Crousore, Partner,  Baker & McKenzie, Palo Alto


4:00 pm – 5:00 pm        The Administrative Procedure Act and the Impact of Challenges to IRS Regulations
Taxpayers increasingly are asking courts to hold Treasury and the IRS accountable to the Administrative Procedure Act provisions and principles that apply to rulemaking by federal agencies.  This session will address the application of this analytical regime by the Supreme Court, the Tax Court, and other courts, the import of such rulings in the evaluation of the validity of Treasury Regulations and other IRS guidance, and the implications of these rulings for other IRS regulations—including those relating to cost sharing buy-in payments. 

Moderator: A. Duane Webber, Partner, Baker & McKenzie, Washington, DC
J. Richard Harvey, Jr., Professor of Practice, Villanova University Charles Widger School of Law School and Graduate Tax Program
Joseph "Jud" Judkins, Associate, Baker & McKenzie, Washington, DC
Richard W. Skillman, Member, Caplin & Drysdale,Ch., Washington, DC


5:00 pm – 7:30 pm         Networking Reception

 
DAY 2: THURSDAY, JUNE 9, 2016


8:00 am - 8:30 am          Breakfast

 

8:30 am – 9:15 am         Corporate Tax Reform. State Aid. Inversions. Whatever's Next on the Minds of Capitol Hill Tax Counsels?

Moderator: Joshua D. Odintz, Partner, Baker & McKenzie, Washington, DC
Barbara M. Angus,
Republican Chief Tax Counsel, House Committee on Ways and Means
Aruna Kalyanam,
Democratic Tax Counsel, House Committee on Ways and Means
J. Todd Metcalf,
Democratic Chief Tax Counsel, Senate Finance Committee
Mark Prater,
Republican Chief Tax Counsel, Senate Finance Committee

9:15 am - 10:00 am         Keynote Address

Robert Stack, Deputy Assistant Secretary for International Tax Affairs, US Treasury

10:00 am – 11:00 am       Application of the Authorized OECD Approach (AOA) to the Attribution of Profits to New Permanent Establishments
As part of the follow-up work to the changes to the OECD Model’s permanent establishment definition under BEPS Action 7, the OECD agreed to provide guidance in 2016 on how the Authorized OECD Approach (AOA) to attributing profits to PEs, which was finalized in 2010, applies in the case of the newly defined PEs.   Many questions have arisen about how the AOA’s focus on “significant people functions” in the attribution of assets and risks will play out in the context of PEs that result from dependent agent activities not rising to the level of contract conclusion, from operations previously protected under “preparatory or auxiliary” exceptions, or from the aggregation of activities conducted by multiple group members.   This panel will explore those questions and will consider the ramifications for multinational companies affected by treaties in which the new PE definitions may be introduced.  

Moderator: Mary C. Bennett, Partner, Baker & McKenzie, Washington, DC
Rafic H.  Barrage, Partner, Baker & McKenzie, Washington, DC
Brian Jenn, Attorney-Advisor, Office of International Tax Counsel, US Treasury
Margaretha Haeussler, Vice President Economic Analysis, Olympus Corporation of the Americas
John Hughes,  Senior Advisor – Transfer Pricing Operations, IRS


11:00 am – 11:15 am       Refreshment Break

11:15 am – 12:15 pm       The Intersection of Customs and Transfer Pricing
Reconciling transfer pricing and customs valuation is an issue all multinationals need to come to grips with, particularly with BEPS implementation on the horizon.  While efforts to harmonize the two valuation methods have made some progress in recent years, key differences remain, which often serve as a trap for the unwary.  Practitioners will share their experiences and discuss best practices to better manage and coordinate the two disciplines so as to minimize potential exposure.

Moderator:  Michael E. (Ted) Murphy, Partner, Baker & McKenzie, Washington, DC
Holly E. Glenn, Principal Economist, Baker & McKenzie Consulting, LLC, Washington, DC
Damon V. Pike, President, The Pike Law Firm
Richard L. Slowinski, Partner, Baker & McKenzie, Washington, DC
Ian Cremer, Head of Valuation, World Customs Organization


12:15 pm – 1:00 pm        Luncheon

1:00 pm – 1:30 pm          Keynote Address

Gert-Jan Koopman, Deputy Director-General for State Aid, European Commission

1:30 pm – 2:30 pm       Recent LB&I Reorganization and the Future of Transfer Pricing Audits
The IRS has restructured its Large Business and International Division with the goal of eliminating the long-standing divide between domestic and international examination functions, reorganizing into nine practice units reporting to a single deputy commissioner. This panel will focus on what these changes mean in practical terms for taxpayers with transfer pricing and other international issues.

Moderator:  Scott H.  Frewing, Partner, Baker & McKenzie, Palo Alto
Sharon Porter,  Director, Treaty and Transfer Pricing Operations, IRS
Daniel A. Rosen, Partner, Baker & McKenzie, New York
Michael Bernard, US Tax Counsel, Microsoft Corporation
Cheryl Teifer, Director of Field Operations – Transfer Pricing Practice, IRS


2:30 pm – 2:45 pm       Refreshment Break


2:45 pm – 4:00 pm       European Union State Aid
The European Commission continues its aggressive probe into U.S. multinationals’ tax agreements with several EU member states. Several of those states, as well as the U.S., have protested this treatment. Panelists from the U.S. government and the private sector will discuss the latest developments in the investigations and their impact on APAs and other tax agreements with the targeted jurisdictions.

Moderator: Mary C. Bennett, Partner, Baker & McKenzie, Washington, DC
Gert-Jan Koopman, Deputy Director-General for State Aid, European Commission
Nina Niejahr, Counsel, Baker & McKenzie, Brussels
Robert Stack, Deputy Assistant Secretary for International Tax Affairs, US Treasury
Catherine Schultz, Vice President for Tax Policy, National Foreign Trade Council

4:00 pm               Conference Concludes

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