2022 72nd Midyear Conference

Mar 20, 2022 ‐ Mar 23, 2022



Sessions

Welcome/Opening Remarks & Conferral of Distinguished Service Award to Deborah Gaffney / Plenary - Letting Imperfect Be The Enemy of Highly Imperfect - U.S. Tax Policy & Legislative Update

Mar 21, 2022 8:00am ‐ Mar 21, 2022 9:30am

Identification: M01

This plenary session will feature an animated roundtable discussion among three of Washington’s top tax lobbyists, who will share their insights regarding the prospects for corporate and international tax reform legislation in the 117th Congress and related tax policy developments off the Hill. Not to be missed!

After attending this session, participants should be able to, among other things: (1) understand the major corporate and international tax reform provisions in H.R. 5376, the Build Back Better Act, as passed by the House of Representatives on November 19, 2021, and the likelihood of their getting enacted into law; (2) identify other Democratic tax legislative priorities (and their prospects) for the second session of the 117th Congress, and (3) understand the Biden administration’s current posture and role in tax policy development, both on and off the Hill.

Speaker(s): Moderator(s): Speaker(s):
Tags: INTL FED

Break iconBreak

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Break

Mar 21, 2022 9:30am ‐ Mar 21, 2022 9:45am

Identification: BK1


Concurrent Sessions iconConcurrent Sessions

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Concurrent Sessions

Mar 21, 2022 9:45am ‐ Mar 21, 2022 10:45am

Identification: CC01


Tax Practice in a Perfect Storm – Assessing the Impacts of Inflation, Supply Chain Disruption, and Legislative Uncertainty on the Tax Function

Mar 21, 2022 9:45am ‐ Mar 21, 2022 10:45am

Identification: M02

The tax function is in the midst of uncertainty on all fronts, ranging from economic recovery to regulatory guidance to domestic and foreign political uncertainty. This session will explore how tax departments are responding to the potential for unmitigated double taxation as a result of the recently issued foreign tax credit regulations and OECD/G20 BEPS guidance, and the impacts of transfer pricing and ESG thereon.

After this session, participants should be able to:

  • Recognize the major challenges facing tax departments in today’s uncertain world of global tax and fiscal policy
  • Understand the major areas of uncertainty with the scope and timing of OECD/G20 BEPS Pillars One and Two
  • Appreciate the major uncertainties in the final foreign tax credit regulations.

Moderator(s):
  • Mr. Kevin M. Jacobs, Managing Director and the National Tax Office Practice Leader, Alvarez & Marsal Taxand, LLC
Speaker(s):
Tags: FED INTL

Significant Legal Developments for Crediting, Deducting, and Amending Research and Experimental Expenditures: What Should I Know and How Should I Respond?

Mar 21, 2022 9:45am ‐ Mar 21, 2022 10:45am

Identification: M03

Aggressive IRS enforcement of research credits and recent legislation impacting the treatment of section 174 research and experimental expenses have resulted in significant legal and administrative changes that may materially impact future return positions. In response, TEI has assembled a team of leading experts to break down the developments and explain their practical impacts. Our panelists will analyze a variety of topics, such as the new, extremely rigorous reporting standards for research credit refund claims, the impact of Little Sandy Coal on determining what expenses qualify for the credit, the new 5-year amortization requirement for section 174 R&E expenses, IRS practice developments and their impacts on how taxpayers claim, document and defend section 41 credits, and technological advances companies should consider to support their research credit studies.

At the conclusion of this course, participants should:

  • Understand the practical impacts of the Little Sandy Coal case on determining what expenses qualify for R&E credits;
  • Be aware of and better able to comply with new specificity requirements for R&E claims;
  • Understand law changes impacting the deductibility of section 174 R&E expenses and how such changes may impact future tax returns;
  • Be better prepared for IRS examinations of research credits;
  • Be aware and able to evaluate the usefulness of technological advances that may improve the collection of data in research credit studies

Moderator(s):
  • Mr. Brian P. Kaufman, TEI Vice President, Region IV - Vice President, Tax Audits & Tax Counsel, Capital One Financial Corporation
Speaker(s):
Tags: IRSAA FED

Speed Round: Everything you Need to Know About the Top State and Local Tax Issues

Mar 21, 2022 9:45am ‐ Mar 21, 2022 10:45am

Identification: M04

As long as the earth rotates on its axis, there will be developments in state and local taxes. This session will provide an update on developments in state corporate income taxation, sales and use taxes, and local taxation. It will cover topics such as what’s new in pass-through entity taxes, NOL usage, remote workers, and more. 

  • Learn about the lastest issues and litigation invovling NOLs.
  • Understand what new PTE taxes means to corporations.
  • Be able to identify the top issue arising from remote workers.

Moderator(s): Speaker(s):
Tags: SALT

Break iconBreak

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Break

Mar 21, 2022 10:45am ‐ Mar 21, 2022 11:00am

Identification: BK2


IRS Progress Update, The Honorable Charles P. Rettig, Commissioner, Internal Revenue Service / Conferral of Honorary Membership to James A. Kennedy

Mar 21, 2022 11:00am ‐ Mar 21, 2022 12:05pm

Identification: M05

The Honorable Charles P. Rettig, Commissioner, Internal Revenue Service, will join TEI for a multifaceted discussion of the agency’s many challenges, measures being taken to resolve the tax return backlog and Service Center delays, plans for the 6% budget increase recently signed into law, and updates on service and enforcement priorities impacting large business taxpayers.

At the conclusion of this session, participants should:

  • Have a better-informed understanding of the significant challenges the IRS faces in today’s environment
  • Be aware of the timeline for resolving the tax return backlog and how it may impact previously filed returns
  • Understand the significant challenges being encountered at IRS Service Centers and thus be better able to work effectively with IRS personnel
  • Gain awareness of the IRS’s plans for increasing staffing and services and how such investments may impact examinations of large business taxpayers
  • Be aware of high-level IRS enforcement priorities and understand how they may impact examinations of large business taxpayers

Speaker(s):
Tags: IRSAA INTL FED

Conferral of Honorary Membership to James A. Kennedy

Mar 21, 2022 11:50am ‐ Mar 21, 2022 12:05pm

Identification: AP1

Speaker(s):

Networking Lunch iconNetworking Lunch

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Networking Lunch

Mar 21, 2022 12:05pm ‐ Mar 21, 2022 1:00pm

Identification: NL01