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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.
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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.
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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:
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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:
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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.
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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.