One of PWBM’s Senior Economists, Richard Prisinzano, will participate in a session of the Bloomberg Tax Leadership Forum titled Choice of Entity Considerations Post-2017 Tax Reform. More information on the event can be found below.
Overview
Preparing Corporate Leaders for 2019
Bloomberg Tax presents the Bloomberg Tax Leadership Forum, an annual forum for senior business executives who need to plan for their business’ growth strategy and fiscal soundness in the coming year.
As always, Bloomberg Tax will leverage the best of tax, trade, and regulatory reporting and analysis, as it showcases conversations between key U.S. and international policymakers, tax and regulatory experts, and leading corporate executives. All just a few days after the mid-term elections!
Join fellow CFOs, VPs of Tax, and General Tax Counsels for timely and highly relevant discussions ranging from the impact of tax reform on trade to taxation in the digital economy to what you can expect to see in 2019 both here and abroad.
Agenda
Agenda subject to change.
7:30 AM Registration Opens
8:15 AM Welcome to the Bloomberg Tax Leadership Forum
Annabelle Gibson, Managing Editor, Federal Tax- U.S. Income and IRS Procedure, Bloomberg Tax
Ronald Dabrowski, Principal and Technical Deputy, Washington National Tax, KPMG
8:20 AM Breakfast with Bloomberg Tax
A preview of the day, through the lens of Bloomberg Tax editorial leaders, covering federal, international and state tax issues. How is Bloomberg Tax addressing the question of, what’s changed after the election?
Christine Boeckel, Deputy Editorial Director, State Tax, Bloomberg Tax
Julie Joy, Senior Fellow, Bloomberg Tax
Margaret Hogan, Tax Law Editor, Bloomberg Tax
Moderator: George Farrah, Executive Editor, Bloomberg Tax
8:50 AM What's Happening in Tax?
Lisa Fitzpatrick, President, Bloomberg Tax
8:55 AM What’s Happening on the Hill?
Explore the future of the tax landscape following the pivotal U.S. 2018 midterm elections after the votes are counted and a winner is declared.
Panelists will discuss the salient tax issues from the winner’s standpoint and share their insights on what could be a continuing battle between Democrats, Republicans, and the White House epicenter.
Hear as engaged parties discuss a way forward that balances U.S. corporate competitiveness with foreign trade policy amid shifting tax and political landscapes.
Jennifer Acuña, Chief Tax Counsel, Senate Committee on Finance (R)
Barbara Angus, Chief Tax Counsel, House Ways and Means Committee (R)
Aruna Kalyanam, Democratic Tax Counsel and Staff Director, House Ways and Means Committee (D)
Tiffany Smith, Chief Counsel, Tax Senate Committee on Finance (D)
Moderator: Allyson Versprille, Hill Reporter, Bloomberg Tax
9:40 AM Networking Break
10:00 AM Choice of Entity Considerations Post-2017 Tax Reform
The sweeping changes under the 2017 tax act significantly altered the calculus for choice of entity determinations. Important factors to consider include the reduced tax rate for corporations as well as the qualified business income deduction for pass-through entities. These and other changes under the new law will heighten the impact of choice-of-entity decisions in 2018 and the future.
Panelists will outline the approaches to weighing the pros and cons of the different types of entities. They will also discuss other factors relevant to the 2017 tax act and the specific characteristics of the business that must be carefully evaluated.
Audrey Ellis, Attorney-Advisor, Department of Treasury, Office of Tax Policy, US Treasury
Richard Prisinzano, Senior Economist, Penn Wharton Budget Model
Brian Reardon, President, S-Corp Association
Alan Tarr, Partner, Loeb & Loeb
Moderator: Scott Hodge, President, Tax Foundation
10:50 AM Spotlight Session on Tax Credits
Alex Tiller, Managing Director, Foss Renewable Energy Partners, LLC
11:05 AM The State of State
Hear from leading state tax practitioners who will explore the future of the state tax landscape following the U.S. Supreme Court’s pivotal decision in the South Dakota v. Wayfair case. Panelists will discuss a mutual path forward for the states and taxpayers, and share their insights and practical guidance for businesses operating in the wake of Wayfair. Engaged parties discuss tax planning strategies to remain competitive and in compliance with dramatically changed and continuously evolving state tax policies.
Joe Bishop-Henchman, Executive Vice President, Tax Foundation
Walt Nagel, Chief Tax Officer, Gannett
Fred Nicely, Senior Tax Counsel, COST
Nancy Prosser, General Counsel, Texas Comptroller of Public Accounts
Marshall Stranburg, Deputy Executive Director, MTC
Moderator: Verenda Smith, Deputy Director, Federation of Tax Administrators
12:00 PM Luncheon
1:00 PM Spotlight Session
The 2017 U.S. tax law added a new provision on Opportunity Zones under section 1400Z, which allows the deferral and partial exclusion of certain gains from the sale or exchange of an asset if those gains are reinvested in a Qualified Opportunity Fund (or QOF) as long as certain requirements are met. There is also the potential for exclusion of future gains on investments in QOFs that are held for at least 10 years. This spotlight session will provide a high-level overview of the issues and planning opportunities surrounding Qualified Opportunity Zones.
Deborah Fields, Partner, KPMG LLP
1:15 PM International Tax Developments: Outlook for 2019
The 2017 tax act fundamentally changed the taxation of U.S. multinational entities with the introduction of a partial participation exemption, a one-time repatriation tax, a minimum tax on foreign earnings of U.S. MNEs with foreign subsidiaries, a base erosion and anti-abuse tax on certain transactions between affiliated corporations, and a variety of other changes, including to the foreign tax credit computation.
Panelists will address the impact of guidance from the US Treasury and IRS to date, as well as further expected guidance and the possibility of more legislation. Panelists will also examine the response outside the U.S., especially among U.S. treaty partners.
Myrtle Jones, Senior Vice President of Tax, Halliburton
Douglas Poms, Senior Counsel to the International Tax Counsel, US Department of Treasury
Agnieszka Samoc, Vice President, Tax Counsel, Danaher Corporation
Moderator: Catherine Schultz, Vice President, Tax Policy, National Foreign Trade Council (NFTC)
2:05 PM The Digitization of Tax – Where Do We Go From Here?
Hear from EU and OECD regulators on the increasing number of countries moving to tax digital companies in an effort to ensure a fair tax regime between online companies and traditional brick-and-mortar businesses—and to ensure a stable revenue basis as the global economy shifts toward e-commerce.
Panelists will include representatives of digital companies and tax industry experts, who will discuss the challenges and uncertainty in adapting to a new tax landscape that is moving at a disruptive pace for businesses.
Parties will consider 2020, when the EU proposes to wind down its current plans for a revenue-based tax on digital companies. That, however, hangs on the condition that the OECD’s policies, expected among final recommendations at the same time, are good enough.
David Bradbury, Head of the Tax Policy and Statistics Division, Centre for Tax Policy and Administration, OECD
Liz Chien, Vice President, Global Tax, Ripple Labs
Timothy McDonald, Vice President-Finance & Accounting, Global Taxes, The Procter & Gamble Company
James Ross, Partner, McDermott Will & Emery UK LLP
Moderator: Carol Doran Klein, VP and International Tax Counsel, United States Council for International Business (USCIB)
2:50 PM Networking Break
3:10 PM Transfer Pricing – A Strategic Planning Imperative Under New U.S. Tax Law
Two seismic shifts in the tax environment, BEPS and the 2017 US Tax Law (TCJA), mean multinational companies are recalibrating their tax planning strategies as never before. How will transfer pricing be affected by the new BEAT, GILTI and FDII rules? Should MNCs change their intercompany pricing policies? Should companies bring back their valuable intangibles to the U.S.? The panel will also look closely at recent developments in state and local transfer pricing enforcement; and with transfer pricing disputes on the rise, the panel will explain what recent judicial decisions mean for litigation strategies going forward.
J. Clark Armitage, Member, Caplin & Drysdale
Brian Jenn, Attorney-Advisor, Office of International Tax Counsel, U.S. Department of Treasury
Ognian Stoichkov, Global Transfer Pricing Director, PepsiCo
Moderator: Julie Joy, Senior Fellow, Bloomberg Tax
3:55 PM Is the U.S. Tax Act a Threat to the International Tax Order?
The passing of the 2017 U.S. Tax Act has created tension on the international stage as the foreign-derived intangible income (FDII) provision and the base erosion and anti-abuse tax provisions (BEAT) are being positioned by the European Union as “harmful tax practice” and potentially discriminating against EU companies. Furthermore, the FDII is being challenged by EU finance ministers as a potentially illegal export subsidy under current WTO rules.
Hear from an esteemed panel of leading tax experts as they discuss the U.S. position that the law does not violate international obligations, the possibility of a World Trade Organization challenge to the law and what outcome taxpayers might expect, including what businesses need to know as they evaluate the risk that FDII may disappear and the ensuing impact on their tax burden on intellectual property income.
Grant D. Aldonas, Executive Director, Institute of International Economic Law, Georgetown University Law Center
Loren Ponds, Member, Miller & Chevalier
Danielle E. Rolfes, Partner, KPMG LLP
Eric Solovy, International Trade and International IP Partner, Sidley Austin LLP
Moderator: Eli J. Dicker, Executive Director, Tax Executives Institute
4:40 PM Closing Remarks
4:45 PM Networking Reception