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2019 May Meeting

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(c) [2019] American Bar Association.
All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of the American Bar Association.

$299.00



Showing sessions 1 - 10 of (42) TOTAL sessions
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Event : ABATX42


Session : ABATX1946
Tax Bridge to Practice
Conference : 2019 May Meeting
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$75.00


  • Program Co-Chairs: Kelley C. Miller, Reed Smith LLP, Washington, DC; Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC
  • A Conversation With... An esteemed member of the tax community and Tax Section sits down for an in-depth discussion of his practice, his history, and the latest developments in tax law.
  • Fifteen (02), There’s Still Time for You: Consolidated Returns Basics. The US consolidated returns rules found primarily under the section 1502 regulations are dizzyingly complex and yet a basic understanding is necessary as a vast number US groups of corporations are subject to the regime. This panel will provide an overview of fundamental concepts that are commonly encountered such as consolidated group membership and termination, intercompany transactions, adjustments to member E&P and stock basis, and special rules with respect to losses. In addition, this panel will discuss the interaction of some of the more prominent tax reform provisions with the consolidated returns rules. Moderator: Alfred Bae, EY, Houston, TX; Panelists: Armita Sobhi, EY, Washington, DC; Hasnain Valika, KPMG, Houston, TXCo-sponsored by: Corporate Tax
  • Statutes of Limitations in Tax Litigation: Friend or Foe? Statutes of limitations are an important, but often overlooked, aspect of tax litigation that can work to the advantage or the detriment of a party. Most practitioners are familiar with the general three-year period of limitation on assessment, as well as basic exceptions, including those for a false return, no return, or a substantial omission of gross income. This panel will address more nuanced rules affecting statutes of limitations in tax, including the interplay of section 6511(a) and (b) in refund suits (and, as appropriate, Tax Court litigation), the failure to notify the IRS of certain foreign transfers, and the failure to disclose listed transactions. The panelists will also discuss strategies for navigating statute of limitation issues in litigation, as well as the effect of the government shutdown on both statute of limitations and filing deadlines with courts and the IRS. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC; Panelists: Paul Butler, Kostelanetz & Fink LLP, Washington, DC; Professor T. Keith Fogg, Director of the Federal Tax Clinic, Harvard Law School, Jamaica Plain, MA; Elie Mishory, Attorney, Office of Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ; Rebecca M. Stork, Eversheds Sutherland LLP, Atlanta, GACo-sponsored by: Court Procedure & Practice and Young Lawyers Division Tax Law Committee
  • This Land is Your Land: An Introduction to the Conservation Easement Tax Deduction. The panelists will discuss the elements of a deductible qualified conservation contribution, how the division of property rights defines this statutory exception to the general charitable contribution rule, and the additional regulatory requirements necessary to satisfy that exception. The discussion will include examples drawn from recent Tax Court opinions and highlight recent guidance.Moderator: Valerie Vlasenko, Agostino and Associates PC, Hackensack, NJPanelists: Anson Asbury, Asbury Law Firm, Atlanta, GA; Karin Gross, Special Counsel, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; Zachary King, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DCCo-sponsored by: Real Estate and Tax Accounting
  • How the Sausage Gets Made: The Unintended Consequences of the 2017 Tax Act and the Outlook for Tax Legislation in 2018. The Tax Cuts and Jobs Act was signed into law by President Trump on December 22, 2017. Originally intended as an amendment to various provisions of the Internal Revenue Code of 1986, the TCJA created a cannon of entirely new, and occasionally baffling, tax law for practitioners. This panel, comprised of Washington, DC tax policy insiders, will focus on how tax legislation—like the TCJA and other legislation currently before Congress—evolves from K Street to conference to committee to Treasury and finally, to law. Notably, the panel will provide insight into the current tax legislation making its way through Congress and the prospects for new tax law in 2018. Panelists: Dawn O’Donnell, D Squared Tax Strategies, Washington, DC; Michael McHugh, Urban Swirski & Associates LLC, Washington, DC; Kelley C. Miller, Reed Smith LLP, Washington, DC; Karishma Page, K&L Gates, Washington, DC; Tara Rao, Franklin Karibjanian & Law PLLC, Washington, DC; Anna K. Ratner, CFP Board, Washington, DC


Session : ABATX1947
Low Income Taxpayer Representation Workshop
Conference : 2019 May Meeting
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$60.00


  • But I’m A TAX Lawyer: Working with Immigration, H2-A and Other Residency Issues. A taxpayer comes to you with an issue that appears to be more immigration than tax related... Don’t panic! This panel will discuss the myriad tax (and non-tax) issues that arise when assisting low-income taxpayers that are not US citizens. From basic issue-spotting, to the 1040NR return, to what other legal resources are available: this panel will provide the tax practitioner with a solid foundation to holistically address the concerns of the non-citizen taxpayer. Moderator: Anastassia Kolosova, Accounting Aid Society, Detroit, MI. Panelists: Lazlo Beh, Philadelphia Legal Assistance, Philadelphia, PA; Rostyslav Shiller, IRS National Taxpayer Advocate Office, Washington, DC; Sulma Guzman, Centro de los Derechos del Migrante, Baltimore, MD
  • Self-Employed In the Online Platform Economy: Navigating EITC Audits From Tax Return to Tax Court. Gig economy workers and independent contractors may face different challenges when they claim the EITC and their returns are audited. This panel will (1) provide an overview how technology (including apps) impact how gig economy and independent contractors receive income or pay expenses; (2) provide some practical advice about how to anticipate challenges at the IRS exams and appeals levels (what issues may be raised, ways to obtain documentation necessary to prove income and/or expenses)and how a client’s EITC can be impacted; and (3) discuss what to anticipate if such a worker litigates a notice of deficiency at the Tax Court, including addressing proof as to whether a client is engaged in a trade or business, challenges under section 6201(d) as to information returns, what documents should be included in stipulations of fact, and evidentiary issues concerning electronic records. Moderator: Soree Finley, Charlotte Center for Legal Advocacy, Charlotte, NC. Panelists: Special Trial Judge Diana Leyden, US Tax Court, Washington, DC; Nancy Rossner, The Community Tax Law Project, Richmond, VA; Elizabeth Shaner, IRS Office of Chief Counsel, Baltimore, MD
  • EITC and Benefits Law: Conceptualizing, Understanding (and Navigating) the Interplay of EITC and Benefits Law. What makes the EITC “different” from other tax provisions? And when do those differences matter (in a legal sense)? This panel will discuss the history and purpose of the EITC, how it interfaces with other disparate areas of law like benefits and bankruptcy. Moderator: Professor Caleb Smith, University of Minnesota Law School, Minneapolis, MN. Panelists: Margot Crandall-Hollick, Congressional Research Service, Washington, DC; Carrie Welton, Center for Law and Social Policy, Washington, DC


Session : ABATX1948
Capital Recovery & Leasing
Conference : 2019 May Meeting
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$30.00


  • Chair: Sam Weiler, EY, Columbus, OH
  • Current Developments and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing, including an update on the bonus depreciation regulations under section 168(k) and the business interest expense limitation regulations under section 163(j). Moderator: Tracy Watkins, RSM, Washington, DC. Panelists: Kathy Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Charles Gorham, Special Counsel, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Scott Dinwiddie, Associated Chief Counsel, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Jaime Park, Attorney, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Selvan Boominathan, CohnReznick, Washington, DC
  • An (Unexpected) Interest in ADS. This panel will discuss the increased focus on the use of the alternative depreciation system in light of various tax reform provisions and related guidance, such as computing foreign derived intangibles income and allocations to excepted and non-excepted businesses under the interest expense provisions of section 163(j). Moderator: Jane Rohrs, Deloitte, Washington, DC. Panelists: Kathy Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Charles Gorham, Special Counsel, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Jaime Park, Attorney, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Justin Grill, Attorney, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC; Gary Scanlon, Attorney-Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; Carol Conjura, KPMG, Washington, DC; Sara Logan, PwC, Washington, DC; Tim Powell, EY, Washington, DC


Session : ABATX1949
Administrative Practice
Conference : 2019 May Meeting
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$45.00


  • Chair: Jennifer Breen, Morgan Lewis & Bockius, Washington, DC
  • Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent legislative efforts impacting tax law and the IRS, Treasury and IRS guidance, court decisions, ongoing litigation and other items germane to tax administration. Moderator: Elizabeth J. Smith, Ropes & Gray LLP, Boston, MA. Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Kathryn Zuba, Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Jim Gadwood, Miller & Chevalier Chartered, Washington, DC
  • Back to Basics: Life Cycle of an IRS Collections Action. This panel will provide an overview of how the IRS institutes and conducts a collection action, and how a taxpayer may respond to such collection action. The panel will provide the perspective of the government and the taxpayer. Discussion points will include collection action process and procedures, types of collection actions, a taxpayer’s ability to challenge a collection action (including the underlying tax liability), and alternatives to IRS collection actions.Moderator: Antoinette Ellison, Jones Day, Atlanta, GA. Panelists: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Alina Solodchikova, RSM US LLP, Washington, DC
  • New Technologies to Communicate with Exam and Appeals. Communication tools have dramatically improved since fax machines first hit the scene. IRS is working to leverage these technologies to improve its communication with taxpayers and advisors, and more efficiently use IRS resources. This panel will explore new technologies that the IRS has recently made available to practitioners in examinations and appeals conferences, including a demonstration of a new web-enabled video conferencing pilot program. Moderator: Rochelle Hodes, Crowe LLP, Washington, DC. Panelists: Travis Thompson, Sideman & Bancroft, San Francisco, CA; Andrew Allen, Morgan Lewis & Bockius, Palo Alto, CA; Andrew J. Keyso, Deputy Chief, IRS Office of Appeals, Washington, DC; Diane Ogawa, Appeals Officer, Honolulu, HI; Nancy Wiltshire, Acting Director Field Operations, Mid-Atlantic, LB&I, Washington, DC; Andrew Chiu, Director of Product Management and User Experience Design, Washington, DC


Session : ABATX1950
Affiliated & Related Corporations
Conference : 2019 May Meeting
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  • Chair: Greg Fairbanks, Grant Thornton, Washington, DC
  • Consolidated Return Aspects of the Tax Code’s Jazziest Acronyms (otherwise known as the TCJA)—GILTI, FDII, 163J, and the BEAT. This panel will review recently proposed regulations concerning the application of the GILTI and FDII rules, as well as the section 163(j) and BEAT rules, in the context of a consolidated group. During this discussion, the panel will provide a brief overview of the substantive rules and a deeper dive into the consolidated return aspects of the proposed regulations. No advance reading required, but please leave any other acronyms at the door! Moderator: Mark Schneider, Deloitte, Washington, DC. Panelists: Joe Pari, Weil Gotshal, Washington, DC; Bill Pauls, Deloitte, Washington, DC; Julie Wang, IRS Chief Counsel, Washington, DC
  • Current Developments. This panel will consider current developments affecting affiliated and related corporations, with significant focus upon section 965 regulations and proposed section 168(k) regulations. Moderator: Don Bakke, EY, Washington, DC. Panelists: Colin Campbell, Department of Treasury, Washington, DC; Armita Sobhi, EY, Washington, DC; Becky Holtje, KPMG, Washington, DC; Austin Diamond-Jones, IRS Office of Chief Counsel, Washington, DC


Session : ABATX1951
Banking & Savings Institutions
Conference : 2019 May Meeting
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$45.00


  • Chair: Yoram Keinan, Kostelanetz & Fink LLP, New York, NY
  • A Comparative Analysis of Treaty Anti-Abuse Provisions and Financial Institutions. In today’s global international markets, financial institutions routinely enter into cross border financial transactions, internally with affiliates and/or with unrelated parties. Thus, it is very important for the transacting financial institution to assess the application of an applicable tax treaty in general, and the treaty’s anti-abuse rule in particular. This comparative panel will present this issue from the perspective of three neighboring countries: The United States, Canada and Mexico in light of the relevant treaties’ provisions, each country’s domestic general anti-avoidance rules and the impact of the Multi-lateral instrument (“MLI”). Moderator: Shay Menuchin, KPMG, Toronto, ON. Panelist: Laura Gheorghiu, Gowling WLG, Montreal, QC; Mariana Eguiarte Morett, Sanchez Devanny, Mexico City, Mexico
  • The Current State of the Economic Substance Doctrine and its Effect on Financial Institutions. The economic substance doctrine was “codified” in 2010, effective for transactions after March 31, 2010, and a new strict liability penalty added for economic substance understatements. While the IRS and Treasury provided initial guidance on the application of the codified doctrine and the penalty, only a handful of cases have considered post-codification transactions. This panel will discuss how the economic substance doctrine has developed since codification and the extent to which the doctrine and the penalty should concern financial institutions in planning and examinations. Moderator: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY. Panelists: Jasper Cummings, Alston & Bird, Washington, DC; James Hartford, IRS Office of Chief Counsel, Washington, DC; Yoram Keinan, Kostelanetz & Fink LLP, Washington, DC


Session : ABATX1952
Estate & Gift Taxes
Conference : 2019 May Meeting
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$45.00


  • Chairs: George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, Florida/Washington, DC; Hannah W. Mensch, Ehrenkranz Partners, New York, NY
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2019. Panelists: Megan M. Curran, Fiduciary Counselling Inc., Tacoma, WA; Beth Kerwin, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
  • The Anatomy of the Form 706-NA. Despite the temporary doubling of the exemption amount to ten million dollars (indexed for inflation) for the estate of a US citizen or US domiciliary, the exemption remains at $60,000 (and not indexed for inflation) for the estate of a noncitizen nondomiciliary under the Internal Revenue Code. This program highlights the technical and practical considerations in the selection, preparation, filing, and audit of the U.S. federal estate tax return (Form 706-NA) and associated IRS forms when a noncitizen nondomiciliary dies with US assets. The program also considers the often overlooked planning strategies to lessen the imposition of federal estate tax and their impact on the filing and preparation of the Form 706-NA return. Panelists: Carmina Y. D’Aversa, Attorney at Law, Radnor, PA; Kevin T. Keen, Winstead PC, Houston, TX
  • Transfer Tax Planning for Tech Entrepreneurs. This panel will discuss the unique challenges tech entrepreneurs present for estate planners and various transfer tax strategies to meet such clients’ needs. More specifically, we will examine ways of removing appreciation in the value of intellectual property and tech business interests from an entrepreneur’s taxable estate while also addressing such entrepreneur’s need for liquidity and fear of discouraging a future company sale or investment. Additionally, this panel will look at the mechanics of such a transfer, including the elements of an effective transfer of intellectual property, corporate and securities law issues to keep in mind and issues pertaining to the valuation of intellectual property or tech company interests. Panelists: Jennifer B. Goode, Birchstone Moore LLC, Washington, DC; Jessica Chod, Potomac Law Group, Washington, DC; Stephanie Johnson, SC&H Group, Baltimore, MD; Kesh Iyer, RSM US LLP, Washington, DC
  • IRS Form 712: Like a Box of Chocolates, You Never Know What You’re Going to Get. This panel will present a primer on IRS Form 712 and the different ways that insurance carriers value policies and reports, when and why it matters, and a discussion of other approaches to valuing life insurance policies for wealth transfer strategies. Panelists: Ashley B. Sawyer, Loeb & Loeb LLP, Washington, DC; Sarah Moore Johnson, Birchstone Moore LLC, Washington, DC


Session : ABATX1953
Investment Management
Conference : 2019 May Meeting
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  • Chair: Roger S. Wise, Willkie Farr & Gallagher LLP, Washington, DC
  • A Potpourri of Private Fund Issues. This panel will focus on recent trends and tax issues facing private investment funds. Topics will include waivers, allocations and the new carried interest rules; unexpected contexts in which loan origination issues can arise; ECI and withholding on sales of partnership interests; FIRPTA planning; withholding tax refunds and reverse hybrid entities; and subscription lines and UDFI. Panelists: Thomas Calianese, EY, New York, NY; Linda Hui, Ares Management Corporation, Los Angeles, CA; Benjamin H. Rippeon, Gibson Dunn & Crutcher LLP, Washington, DC; Laura Warren, Hamilton Lane, Bala Cynwyd, PA
  • Business Development Company (BDC) Structuring and Trends. This panel will discuss the regulatory scheme for BDCs, tax and securities law structuring considerations, and recent market trends. Panelists: James Brown, Ropes & Gray LLP, New York, NY; David Roby, Eversheds Sutherland (US) LLP, Washington, DC; James Silk, Willkie Farr & Gallagher LLP, Washington, DC
  • Looking Behind the Curtain on Opportunity Zones: Risks to OZ Stakeholders from Implementation Issues and Potential Reporting and Anti-Abuse Rulemaking. Lack of reporting, data collection or community impact requirements is leading to concerns about gentrification and that OZ could become an unintended tax shelter. This panel of policy, legal and community engagement thought leaders will discuss ongoing implementation issues, prospects for reporting and anti-abuse rulemaking at the federal and local levels, and the potential legal and reputational risks they pose for unwary OZ investors, developers, entrepreneurs and fund sponsors. Moderator: Mary Burke Baker, K&L Gates, Washington, DC. Panelists: Shafron (Shay) Hawkins, Legislative Assistant, U.S. Senator Tim Scott (R-SC), Washington, DC; William A. Levy, Kirkland & Ellis LLP, Chicago, IL; David Morgan, David Morgan & Partners and founder, National Infrastructure Investment Alliance, Washington, DC


Session : ABATX1954
Partnerships & LLCs
Conference : 2019 May Meeting
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  • Chair: Jennifer Alexander, Deloitte Tax LLP, Washington, DC
  • Hot Topics. This panel will discuss recent developments in the area of partnership taxation, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Deborah Fields, KPMG, Washington, DC. Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Audrey Ellis, Attorney-Advisor, Office of Legislative Counsel, Department of Treasury, Washington, DC; Steven Gilbert, Deloitte Tax LLP, Washington, DC
  • What is a Guaranteed Payment? The classification of a distribution or an entitlement from a partnership as a guaranteed payment has become increasingly relevant in light of tax reform. This panel will discuss the uncertainty surrounding whether certain distributions or entitlements from a partnership should or should not be treated as guaranteed payments. Moderator: Julie M. Marion, Latham & Watkins LLP, Chicago, IL. Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Matthew Arndt, PwC, Washington, DC
  • Unitary Basis Rules and Rev. Rul. 84-53. This panel will discuss the unitary basis rules applicable to partnership interests and the continued relevance and application of these rules. Panelists: Monte A. Jackel, Washington, DC; Eric B. Sloan, Gibson, Dunn & Crutcher LLP, New York, NY


Session : ABATX1955
Tax Policy & Simplification
Conference : 2019 May Meeting
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  • Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • Tax Simplification: A Viable Goal for Tax Reform or a Fantasy? This Committee is the Committee on Tax Policy and Simplification, but it is unclear whether “Simplification” is intended to be a co-equal or a subset of “Policy.” It is also unclear what simplification might be envisioned. Simplification of the Internal Revenue Code and the forms to be filed comes to mind, although a smaller 1040, literally, is not a major simplification. The regulations and other guidance might be simplified, as might the audit and collection processes. Overall, not much simplification has happened historically or seems likely. Why not? Of course, simplification is at odds with the complexity of the society subject to the income tax. More telling, however, is the fact that simplification is often at odds with other goals of tax legislation, such as measuring income so as to achieve horizontal and vertical equity. Real simplification only tends to result when a strong constituency will benefit, despite the fact that the simplification undermines other tax policy goals. This program will discuss these issues with a focus on examples from the numerous historical changes in depreciation and cost recovery provisions of the Internal Revenue Code. It is hoped that this will be a first step toward more focus on simplification that improves the overall income tax. Speaker: Professor Michael B. Lang, Chapman University Fowler School of Law, Orange, CA
  • Digital Discord: Forging Tax Rules to Fit a Digitalized World. As business models and transactions become increasingly digitalized, longstanding domestic tax rules, tax treaties, and international tax norms are being challenged in ways that are both unprecedented and fundamental. Unilateral approaches being advanced by tax policy and law makers are disrupting current tax law paradigms; distorting business decisions; and threatening to subject taxpayers and transactions to increasing levels of double tax, tax disputes, and unanticipated costs. The lack of a global consensus on how to tax our increasingly digitalized economies could also leave a confusing patchwork of conflicting tax policies. The panel will first describe the web of multifaceted tax policy and political issues, and then address specific topics including: the longstanding international tax consensus, forged in the 1920s, on which thousands of tax treaties are based; details of the OECD’s recent “Pillar One” and “Pillar Two” Proposals”; an update on various jurisdictions’ unilateral measures; the official US response to these measures (and the possibility of de facto retaliation); how the US Supreme Court’s decision in South Dakota v. Wayfair (2018) fits into this broader international tax debate; and finally, what tax planners and businesses should be doing now to prepare for what could be drastic changes in how businesses and individuals are taxed in our increasingly digitalized world. Moderator: Pamela A. Fuller, Royse Law Firm, New York, NY. Panelists: Peter H. Blessing, New York, NY; Professor Allan Erbsen, University of Minnesota Law School, Minneapolis, MN; Brian Jenn, Attorney Advisor, Office of International Tax Policy, Department of Treasury, Washington, DC (Invited); Will Morris, PwC and Chair of the BIAC Tax Committee (Business and Industry Advisory Committee to the OECD), Washington, DC; Mansi Seth, Dechert LLP, New York, NY



     


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(c) [2016] Digital Conference Providers, Inc. All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of Digital Conference Providers, Inc. All sales are final and are intended for individual use.