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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.
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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.
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Identification: WA01
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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:
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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.
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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.
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