2022 72nd Midyear Conference

Mar 20, 2022 ‐ Mar 23, 2022

Concurrent Sessions

Preview Available

Concurrent Sessions

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm

Identification: CC02

The Next Frontier in State Transfer Pricing

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The Next Frontier in State Transfer Pricing

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm

Identification: M06

This session will focus on current state and local tax developments relating to transfer pricing, including recent decisions and approaches that states have been employing to bring money into their jurisdiction. It will also discuss best practices for preparing for and defending against such actions.

• Learn about how states are looking at transfer pricing issues.
• Learn about special state programs and initiatives that involve transfer pricing.
• Know about transfer pricing audits and litigation.

Moderator(s):

• Ms. Michell Rodriguez, Director, Corporate Tax, Costco Wholesale Corporation

Speaker(s):

• Ms. Maria P. Eberle, Partner, Baker McKenzie
• Mr. Joe Garrett, Deloitte Tax LLP
• Mr. Clark Calhoun, Senior Associate, Alston & Bird
• Ms. Jessica Morgan, Senior Manager, National Tax, Ernst & Young LLP

Planning for the Proposed Shift to Per-Country Application of GILTI and FTC Limitations

Preview Available

Planning for the Proposed Shift to Per-Country Application of GILTI and FTC Limitations

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm

Identification: M07

This session will discuss how multinational enterprises should prepare to address the potential implementation of a per-country limit on foreign tax credits and GILTI. Both changes present planning opportunities and risks, as well as significant compliance issues.

Learning Objectives:

• Understand the implications of per-country limits on the FTC and GILITI
• Assess what advance planning opportunities and risks are or might be available to their company
• Determine the compliance issues associated with FTC and GILTI limits with the greatest impact on their company.

Moderator(s):

• Mr. Peter Waterstreet, Senior Director, International Tax, VMware, Inc.

Speaker(s):

• Mr. J. Brian Davis, BakerHostetler LLP
• Mr. Stephen R. Bates, Principal - National Tax - International Tax & Transaction Services, Ernst & Young LLP
• Mr. Reed Kirschling, Deloitte Tax LLP

Addressing Risk from Uncertain Tax Positions

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Addressing Risk from Uncertain Tax Positions

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm

Identification: M08

The resources being dedicated to identifying, documenting, and disclosing uncertain tax positions (UTPs) have been steadily increasing for several years, attributable, in part, to unprecedented new complexities in tax laws, incomplete guidance, and increasing demands for clarification from outside accountants. UTPs raise a variety of challenging issues many of which require judgment and all of which carry material consequences for errors. In this session, we’ve assembled a diverse group of seasoned tax and accounting practitioners to address what an in-house tax department should consider when facing risk attributable to uncertain tax positions. Our panelists will address UTPs arising in a variety of different contexts (e.g., uncertain tax authorities, unresolved controversies, tax planning), trends in documenting and substantiating UTPs, and the role of tax opinions and their impact on privilege claims to resist disclosure of confidential communications.

At the conclusion of this course, participants should:

• Understand the financial accounting standards for reporting tax reserves;
• Understand the U.S. federal income tax requirements to disclose uncertain tax positions and how to apply them in a variety of contexts;
• Be aware of procedural issues surrounding the compelled disclosure of audit and tax accrual workpapers and how to navigate them in practice;
• Understand the scope and limitations of and best practices for asserting privilege to protect against government attempts to compel disclosure of documents and other communications
  

Moderator(s):

• Mr. Cliff A. Mangano, TEI Houston Chapter

Speaker(s):

• Ms. Jennifer Breen, Morgan, Lewis & Bockius LLP
• Mr. Al Cappelloni, MBA/ CPA, Tax Partner, RSM US LLP
• Mr. Joshua Wu, Latham & Watkins LLP
• Mr. Randy Buchanan, Eversheds Sutherland (US) LLP

Break

Preview Available

Break

Mar 21, 2022 2:00pm ‐ Mar 21, 2022 2:15pm

Identification: BK3

Concurrent Sessions

Preview Available

Concurrent Sessions

Mar 21, 2022 2:15pm ‐ Mar 21, 2022 3:15pm

Identification: CC03

Managing the Discontinuation of LIBOR from a Tax Perspective – Important Technical and Practical Considerations

Preview Available

Managing the Discontinuation of LIBOR from a Tax Perspective – Important Technical and Practical Considerations

Mar 21, 2022 2:15pm ‐ Mar 21, 2022 3:15pm

Identification: M09

This session will provide an overview of the federal income tax consequences of the transition away from the use of certain interbank offered rates in debt instruments, derivative contracts, and other contracts, exploring the proposed and final Treasury regulations and Revenue Procedure 2020-44, as well as scenarios to which they may or may not apply.

After this session, participants will be able to:

• Understand federal income tax considerations associated with the discontinuation of LIBOR;
• Identify applicable Treasury/IRS guidance in this area
• Appreciate key tax issues that may arise during the transition away from the use of LIBORs.

Moderator(s):

• Ms. Julia Lagun, Member, TEI's Federal Tax Committee and SVP, Corporate Tax Director, Comerica, Comerica Incorporated

Speaker(s):

• Mr. Charles R. Bogle, Partner, Morgan, Lewis & Bockius LLP
• Mr. Russell E. Nance, Mayer Brown LLP

Aligning Tax and IT on Major Tax System Implementations

Preview Available

Aligning Tax and IT on Major Tax System Implementations

Mar 21, 2022 2:15pm ‐ Mar 21, 2022 3:15pm

Identification: M10

This session will discuss best practices in aliging a company's tax department with the IT department when planning for, developing, and implementing changes to IT systems in general, and tax-specific IT systems in particular.

Learning Objectives:

• Understand the major issues surrounding IT systems changes
• Assess the appropriate level of involvement for the tax department in major IT systems implementation
• Determine the necessary touchpoints the tax departments needs to ensure its interests are taken into account when a company prepares for and implements IT changes

Speaker(s):

• Mr. Jason Roberts, Avalara, Inc.
• Mr. Jamie Eagan, insightsoftware
• Mr. Benjamin R. Shreck, Tax Counsel, Tax Executives Institute
• Ms. Kelly Necessary, Partner, Dixon Hughes Goodman LLP

The Locals are Here to Stay: An Update on Local Taxes and Fees Expansion and Litigation

Preview Available

The Locals are Here to Stay: An Update on Local Taxes and Fees Expansion and Litigation

Mar 21, 2022 2:15pm ‐ Mar 21, 2022 3:15pm

Identification: M11

This session will cover significant local tax developments, including heightened enforcement of special taxes and the application of local taxes to increasingly complex businesses and technologies. In addition, the presenters will review local administration issues and cover strategies for compliance.

• Identify significant local tax developments and national trends.
• Understand what businesses and industries are being affected most by special taxes and which localities are imposing special taxes.
• Learn how to best strategize and defend against local tax audits.
  

Moderator(s):

• Mr. Walter B. Doggett, III, Executive Tax Director, E*TRADE Financial Corporation

Speaker(s):

• Ms. Liz Cha, Eversheds Sutherland (US) LLP
• Mr. David Pope, Partner, Baker McKenzie
• Ms. Jennifer S. White, Partner, Reed Smith LLP

Break

Preview Available

Break

Mar 21, 2022 3:15pm ‐ Mar 21, 2022 3:45pm

Identification: BK4