The Corporate Tax Practice: Responding to the New Challenges of a Changing Landscape

5th Annual Tax Policy & Practice Symposium
February 11 - 12, 2004
The Renaissance Washington D.C. Hotel


Day 1
10:00AM - 10:15AM

Welcoming Remarks and Recognition of Symposium Mission

Douglas Bates, Northwestern Mutual Life Richard E. Andersen, Arnold & Porter Lindy L. Paull, PricewaterhouseCoopers LLP
10:15AM - 10:45AM

The Evolution of the Corporate Tax Practice How Did We Get Here?

This address will focus on the evolution of tax policy and tax administration surrounding the role of corporate tax planning. The key judicial, administrative, and legislative developments leading up to the Sarbanes-Oxley Act, reportable transaction disclosure regulations, and proposed tax shelter and post-Enron legislation will be reviewed. This address will provide a broad overview of the challenges and tough issues facing corporate tax executives in the current environment. Keynote Speaker Larry Langdon, Mayer, Brown, Rowe & Maw
10:45AM - 12:15PM

The Corporate Tax Department Managing in the Sarbanes-Oxley Era

This session will examine the policy behind and the practical ramifications of the required increase in executive management focus on tax accounts. A five-member panel will address the tax department's role in connection with the Section 302 quarterly certifications; Section 404 documentation of and attestation on internal controls; and the potential impact on the department's relationship with the audit committee and senior management. Keynote Speaker Bill Gradison, Commissioner Public Company Accounting Oversight Board Moderator Michael Boyle, Microsoft Corporation Panelists Rick Berry, Partner, PricewaterhouseCoopers Geoffrey F. Aronow, Arnold & Porter Larry Quimby, PricewaterhouseCoopers, LLP James Whitson, Delphi Corporation
12:30PM - 1:45PM

Luncheon and Keynote Address

Keynote Speaker Paul S. Atkins, Commissioner U.S. Securities and Exchange Commission*
1:45PM - 3:45PM

Expanding Disclosure Demands The Impact on Tax Accruals

This five-member panel will explore trends experienced in financial restatements, SEC comment letters and enforcement actions, as well as emerging issues involving disclosure and transparency with respect to tax accruals. The panelists will debate the level of documentation and company approval that is required for tax contingency reserves, APB 23 assertions, and internal controls. The Critical Accounting Policies, FAS 5, Regulations S-X, and MD&A disclosure requirements will be addressed. Keynote Speaker Donald Nicolaisen, Chief Accountant U.S. Securities and Exchange Commission Moderator Robin Beran, Caterpillar Inc. Panelists Richard E. Baltz, Arnold & Porter Kenneth Petrini, Air Products & Chemicals,Inc. Richard Jones, Ernst & Young Rita Benassi, Deloitte & Touche
4:00PM - 6:00PM

Attorney-Client Privilege and Transparency Can they Co-exist

This session, led by a judge from the U.S. Tax Court, will present a review of the evolution of the attorney-client and tax advisor privileges, as well as observations on the current state of affairs. Panelists will provide insight into positions on legal privilege from various perspectives, allowing participants to consider these issues from the point of view of the Internal Revenue Service, law firms, independent auditors and in-house counsel. Keynote Speaker The Honorable Thomas B. Wells, Chief Judge US Tax Court Moderator John Samuels, General Electric Company Panelists James P. Joseph, Arnold & Porter Robert L. Moore II, Miller & Chevalier
6:00PM - 10:00PM

Reception, Dinner and Keynote Address

Keynote Speaker Honorable Michael G. Oxley (R-OH), Chairman House Committee on Financial Services Introduction by: Honorable William Archer, Former Chairman House Committee on Ways & Means
68:0PM - 10:00AM


Day 2
10:15AM - 12:15PM

Global Effects of U.S. Reform Dealing in Foreign Jurisdictions

The global reach of Sarbanes-Oxley and the tax shelter disclosure regulations, together with a growing treaty network and increased cooperation among competent authorities make it essential for corporate tax departments to adopt an integrated worldwide approach to tax planning, both from a substantive point of view and from the perspective of defending structures and transactions from attack under widely differing theories. This seven-member panel will bring a global perspective to the challenges facing the tax functions within U.S. and non-U.S. multinationals. Moderator Roger Wheeler, General Motors Corporation Presenter Carol Dunahoo, Baker & McKenzie Panelists Matthew McKenna, PepsiCo, Inc. Nanci Palmintere, Intel Corporation Brian Arnold, Goodmans LP Nishith Desai, Nishith Desai Associates Friedhelm Jacob, Hengeler Mueller
12:30PM - 1:45PM

Luncheon with Keynote Address

Keynote Speaker Mark W. Everson, Commissioner Internal Revenue Service
1:45PM - 3:15PM

The Future Corporate Tax Practice Where Do We Go From Here?

The "avalanche of transparency" discussed in the previous sessions has resulted in a significant increase in the demands of and pressure on the corporate tax department. In this session, six panel members will focus on tax planning in this new environment and will explore ways in which corporations can effectively manage tax risk in the future. Moderator Joseph Luby, Exxon Mobil Corporation Presenters Lindy L. Paull, PricewaterhouseCoopers LLP Joseph Pari, Dewey Ballantine Robert H. Perlman, PricewaterhouseCoopers LLP Panelists Elizabeth Hullinger, The Rouse Company Thomas Cornell, Mars, Incorporated Norma J. Lauder, Bank One
3:15PM - 3:30PM

Concluding Remarks

Douglas Bates, Northwestern Mutual Life Richard E. Andersen, Arnold & Porter Lindy L. Paull, PricewaterhouseCoopers LLP
68:0PM - 69:5PM

Keynote Address

Keynote Speaker Honorable Charles Grassley (R-IA), Chairman Senate Committee on Finance
69:5PM - 10:00AM

Working with the IRS A New and Dynamic Relationship

This session will be devoted to developing a better understanding of the Internal Revenue Service Priorities and related enforcement initiatives. The panel will address the stresses being placed on relationships with the IRS as a result of changing priorities and emerging initiatives. Panelists will provide insight into what corporate executives can expect of the IRS in this new and dynamic environment and will explore ways to improve taxpayer-IRS relationships. Moderator Del Threadgill, J.C. Penney Company, Inc. Panelists Tim Throndson, PricewaterhouseCoopers George K. Yin, Joint Committee on Taxation* Nicholas J. DeNovio, Internal Revenue Service Frank Ng, Internal Revenue Service David Lewis, Eli Lilly & Company Deborah Lange, Oracle Corporation