2022 72nd Midyear Conference

Mar 20, 2022 ‐ Mar 23, 2022

CTO Breakfast – Will This Be on Fox News? What CTOs Need to Know About Congressional Investigations (In-Person Only)

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CTO Breakfast – Will This Be on Fox News? What CTOs Need to Know About Congressional Investigations (In-Person Only)

Mar 22, 2022 7:00am ‐ Mar 22, 2022 8:00am

Identification: T00

Mr. Schoenecker, who previously served as lead investigator for the Senate Committee on Finance’s recent investigation of syndicated conservation-easement transactions and as tax counsel for the House Committee on Ways and Means during the 2017 tax-reform effort, will join us to discuss Congressional policy advocacy, how it intersects with Congressional investigations, and how a Congressional tax investigation differs from tax litigation.

Speaker(s):

• Mr. John L. Schoenecker, Counsel, U.S. Senate Committee on the Judiciary

Welcome and Conferral of Honorary Membership to C.N. (Sandy) Macfarlane / OECD Pillars 1 & 2: Where Do We Stand?

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Welcome and Conferral of Honorary Membership to C.N. (Sandy) Macfarlane / OECD Pillars 1 & 2: Where Do We Stand?

Mar 22, 2022 8:00am ‐ Mar 22, 2022 9:30am

Identification: T01

This plenary session will assess the state of play regarding the OECD's Pillars 1 & 2 project, including the view of the U.S. government, issues still to be addressed and questions to be answered, as well as predictions on how the process will proceed going forward.

Learning Objectives:

• Identify the major political and tax issues that need to be addressed before the OECD can reach consensus on Pillars 1 & 2
• Understand the overall approach of Pillars 1 & 2 to combating the risks of multinational enterprise tax planning
• Determine the major issues of concern to their company's tax position and planning

Speaker(s):

• Mr. Wayne Monfries, SVP Global Taxes, Visa, Inc.
• Mr. C.N. (Sandy) Macfarlane, Past International President, Tax Executives Institute

Moderator(s):

• Ms. Josephine L. Scalia, Treasurer, Tax Executives Institute, Nestle Health Science

Speaker(s):

• Mr. Gary D. Sprague, J.D., Partner, Baker McKenzie
• Ms. Quyen Huynh, Principal, Washington National Tax-International, KPMG LLP
• Mr. Scott Stewart, Mayer Brown LLP
• Mr. Itai Grinberg, Deputy Assistant Secretary for Multilateral Tax, United States Department of the Treasury

Welcome and Conferral of Honorary Membership to C.N. (Sandy) Macfarlane

Preview Available

Welcome and Conferral of Honorary Membership to C.N. (Sandy) Macfarlane

Mar 22, 2022 8:00am ‐ Mar 22, 2022 8:15am

Identification: WA01

Speaker(s):

• Mr. Wayne Monfries, SVP Global Taxes, Visa, Inc.
• Mr. C.N. (Sandy) Macfarlane, Past International President, Tax Executives Institute

Break

Preview Available

Break

Mar 22, 2022 9:30am ‐ Mar 22, 2022 9:45am

Identification: BK7

Concurrent Sessions

Preview Available

Concurrent Sessions

Mar 22, 2022 9:30am ‐ Mar 22, 2022 10:30am

Identification: CC06

R&D Tax Credits: The Ever Changing Research Credit Landscape, Potential New Qualification and Documentation Requirements, and Research Credit Best Practices

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R&D Tax Credits: The Ever Changing Research Credit Landscape, Potential New Qualification and Documentation Requirements, and Research Credit Best Practices

Mar 22, 2022 9:45am ‐ Mar 22, 2022 10:45am

Identification: T02

Navigating a research credit position through the federal income tax lifecycle is becoming increasingly challenging and complex. Join our panelists as they discuss how recent IRS guidance and practices impact claiming the research credit on original returns and in connection with refund claims, issues that IRS Exam Teams have raised during recent audits, and steps that you might want to consider for future filings. This session will include practical tips and tricks, best practices, and ways to ensure your credit filing risks are minimized.

At the conclusion of this course, participants should:

• Understand the new requirements for research credit refund claims and be equipped with best practices for complying with them
• Have a greater understanding of Exam’s new approach to examining research credits and be better prepared to manage such examinations
• Be equipped with strategies for addressing burdensome IDRs and emboldened specialists and making a record for Appeals review of unagreed issues
• Gain a comprehensive understanding of factors to consider when balancing the resources invested in identifying, developing, and documenting a research credit position against the risks and costs of defending the position and best practices for doing so

Moderator(s):

• Mr. Robert L. Howren, CPA, VP of Tax, Aveanna Healthcare

Speaker(s):

• Mr. Nathan Clukey, Tax Partner, Sidley Austin LLP
• Ms. Shelby S. Ford, CPA, Partner, R&D Practice Leader, Crowe LLP
• Mr. Jason Massie, CPA, ESQ., Founder and President, MASSIE R&D Tax Credits

It's All About Substance – Revisiting DEMPE and Related Substance Requirements in a Pillar Two/BBBA World

Preview Available

It's All About Substance – Revisiting DEMPE and Related Substance Requirements in a Pillar Two/BBBA World

Mar 22, 2022 9:45am ‐ Mar 22, 2022 10:45am

Identification: T03

This session will address the current state of the OECD's so called "DEMPE" substance requirements for attributing income from intellectual property to a company's operations in a particular jurisdiction. Discussion will include how to approach DEMPE in light of the OECD Pillar 2 and potential U.S. tax changes that have been recently proposed.

Learning Objectives:

• Understand the basic requirements of the OECD's DEMPE rules.
• Assess how the DEMPE rules may interact with OECD Pillar 2 and proposed U.S. tax changes
• Determine how DEMPE, Pillar 2 and potential U.S. tax changes apply, or would apply, to their company's tax operations.

Moderator(s):

• Mr. Cliff A. Mangano, TEI Houston Chapter

Speaker(s):

• Mr. Michael S. Lebovitz, Partner, Mayer Brown LLP
• Mr. David J. Fischer, Crowell & Moring LLP
• Mr. William R. Skinner, Partner, Fenwick & West LLP

All Things Digital – The Global Taxation of Digital Goods and Services

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All Things Digital – The Global Taxation of Digital Goods and Services

Mar 22, 2022 9:45am ‐ Mar 22, 2022 10:45am

Identification: T04

Maryland is the first U.S. state to impose a tax on digital advertising services, which is partially based on concepts discussed worldwide. The bill faced turmoil from its inception and ultimately passed only after the legislature overrode the governor’s veto. Within a week of passage, the first of two lawsuits challenging the constitutionality of the legislation was filed. Despite pending cases, the Maryland Comptroller issued regulations in late-2021 implementing the new tax. Moreover, other states such as Texas, West Virginia, New York, and Massachusetts are advancing legislation similar to Maryland’s and some experts estimate that more states will consider bills in 2022. This panel discussion will cover the potential outcome of the Maryland litigation and assess the likelihood of future state taxes on digital advertising.

• Learn about worldwide trends in the taxation of digital goods.
• Receive updates on the status of litigation challenging digital advertising taxes.
• Hear about predictions for the future of digital taxes.

Moderator(s):

• Mr. Jeffrey Friedman, Partner, Eversheds Sutherland (US) LLP

Speaker(s):

• Ms. Rene' Blocker, Practice Lead, Indirect Taxes, Bloomberg Tax
• Ms. Leah Durner, Principal, KPMG LLP
• Professor Richard Pomp, Professor of Law, NYU Law School/University of Connecticut Law School

Break

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Break

Mar 22, 2022 10:45am ‐ Mar 22, 2022 11:00am

Identification: BK8

Concurrent Sessions

Preview Available

Concurrent Sessions

Mar 22, 2022 11:00am ‐ Mar 22, 2022 12:00pm

Identification: CC07