The Gathering Storm: 2025 and the Coming Tax and Fiscal Showdown

Continental Breakfast and Registration

Welcome Remarks and Recognition of Symposium Mission

The TCJA Six Years On: Economic and Policy Lessons Learned

It has been six years since passage of the $1.5 trillion Tax Cuts and Jobs Act (TCJA). The TCJA drastically reduced the corporate tax rate, fundamentally reformed U.S. taxation of international income, and significantly reduced individual taxes. Some changes were temporary or delayed, creating uncertainty. The panel will discuss the effect of these changes on the economy, with particular attention to the effect on economic growth, the magnitude and location of investment, development and migration of intellectual property, and corporate tax receipts.

Moderator:
Marty Sullivan, Chief Economist, Tax Analysts
Speakers:
Christine Dobridge, Principal Economist, Federal Reserve Board of Governors
Tadd Fowler, Senior Vice President – Treasurer and Global Tax Operations, Procter & Gamble
Karl Russo, Principal, National Economics and Statistics Leader, PwC

Current State of the Economy

Remarks by Phillip Swagel, Director, Congressional Budget Office.

Break

Debt, Deficits, and Revenues: Implications for Tax Policy

The CBO is projecting growing deficits and debt on a trajectory many characterize as unsustainable. Deficits are estimated to increase from 5.6% of GDP in FY2024 to 6.1% of GDP by 2034, while debt is projected to grow from 99% of GDP in 2024 to 116% by 2034. Longer-term projections continue this trend line. This panel will discuss the economic impact of this fiscal instability, potential tax solutions, and political obstacles.

Moderator:
Nadiya Beckwith-Stanley, Associate, Tax, Skadden, Arps, Slate, Meagher & Flom
Speakers:
Jennifer Acuna, Principal, Federal Tax Legislative and Regulatory Services, KPMG
Marc Goldwein, Senior Vice President and Senior Policy Director, Committee for a Responsible Federal Budget
Hank Gutman, Of Counsel, Ivins Phillips & Barker
Mark Mazur, former Assistant Secretary for Tax Policy, U.S. Department of the Treasury

The Outlook and Implications for the TCJA Expiring Tax Provisions

Over 25 tax provisions from the Tax Cuts and Jobs Act are scheduled to expire at the end of 2025. These provisions will have a broad impact on stakeholders of every type, from the low-income individual to the large multinational corporation, and everything in between. This panel will consider the multitude of policy options that are available to lawmakers as they begin negotiating a tax package to address this massive disruption to the tax code. The panel will highlight the trade-offs that likely will be weighed in this multi-year legislative exercise. The panel also will explore the real-world ramifications of policy options including corporate tax base broadeners. Finally, the panel will discuss the economic impact of Congressional inaction.

Moderator:
Ken Goldberg, Vice President, Tax, International Paper
Panelists:
Mary Duffy, Managing Director, Andersen
Christopher H. Hanna, Alan D. Feld Endowed Professor of Law and Altshuler Distinguished Teaching Professor, Southern Methodist University
Richard Rubin, U.S. Tax Policy Reporter, The Wall Street Journal
Anna Taylor, Deputy Leader - Tax Policy Group, Washington National Tax, Deloitte Tax

Lunch & Presentation of the 2024 TCPI Pillar of Excellence Award

Award Recipient: Harry L. (Hank) Gutman

In the Shadow of the Storm: Treasury’s Guidance Agenda Sails On

This session will begin with a review of recent significant guidance issued by Treasury and the IRS, and a discussion of guidance perhaps still coming, including whether certain guidance (e.g., guidance under the Inflation Reduction Act or targeting perceived abuses) may be accelerated because of the impending 2024 elections. Panelists will consider whether particular items of guidance may or may not be within Treasury’s regulatory authority, as well as possible limitations under the Congressional Review Act. In addition, the potential impact of changes in Treasury and IRS leadership, and reductions in IRS funding, will be examined. Finally, panelists will debate whether the Chevron challenge currently before the Supreme Court may affect this Treasury’s (or future Treasury’s) regulatory agenda. Throughout the session, the issue of how tax directors can be in the best position to manage the risks associated with all of these variables will be discussed.

Moderator:
Mary Kim Elkins, Senior Vice President, Taxes, Eaton
Speakers:
Micah Green, Senior Counsel, Steptoe
Keith Martin, Co-leads, Projects, Norton Rose Fulbright
Joe Reese, Vice President and Chief Tax Officer, NextEra Energy, Inc.
Tom West, former Deputy Assistant Secretary for Tax Policy, U.S. Department of the Treasury

The Rising Tide of Disclosures: How Will Companies Navigate Tax Disclosure Mandates in the Uncertainty of the Coming Tax Agenda?

Around the world, tax disclosure mandates are proliferating at the very time that companies face great uncertainty as to the future of the global tax system. These twin challenges raise a pivotal question: how can companies navigate these unknowns while still meeting the call for greater tax disclosures?

This panel will unravel the origins of the disclosure trend and ask whether the current state accomplishes those original goals. Furthermore, the panel will explore practical steps to meet the challenge of the coming disclosure mandates, including managing the large amounts of data required, communicating results to various stakeholders, and using the information to interface with policymakers.

Moderator:
Sharon Katz-Pearlman, Shareholder, Greenberg Traurig
Speakers:
Melissa Hall, Senior Vice President, Assurant
Ed Paul, Vice President and Controller, Lockheed Martin Corporation
Urvi Doshi Sood, Vice President, Taxes & General Tax Counsel, Lockheed Martin
Ashley Winston, Founder and CIO, Phylleos

Break

The Brave New World of Profit Allocation Post-Pillar One

The proliferation of new taxes on the digital economy since BEPS 2.0 was launched in 2019 has slowed while, at the same time, other new approaches to sourced-based taxation have emerged. The panel will recap these developments, discuss how to build on the OECD efforts to develop a net-based alternative to gross-basis taxes, and reflect on where profit allocation rules/ source-based taxation might head from here.

Moderator:
Loren Ponds, Member, Miller & Chevalier
Speakers:
Lilian Faulhaber, Vice Dean and Ralph H. Dwan Chair in Taxation, Georgetown Law
Michael McDonald, Managing Director, International Tax and Transaction Services – Transfer Pricing, EY
David Paul, AVP Tax, American Honda Motor Company, Inc.
Michael Plowgian, Principal, Washington National Tax, KPMG

The New Global Competition for Capital and Investment: What Does a Post-Pillar 2 World Look Like?

Implementation of OECD Pillar 2 is quickly changing the international tax landscape in ways that have yet to be fully realized. Despite the changes, one thing that will remain constant is the desire of countries to attract capital and investment from multinational corporations. This panel of senior international tax experts and senior tax executives will discuss how the competition for capital and investment is likely to continue in a post-Pillar 2 world. How can countries create and implement stable and attractive Pillar 2 alternatives to traditional tax incentive? What impact will the post-Pillar 2 landscape have on companies’ effective tax rates and how tax rates are viewed?

Moderator:
David Noren, Partner, McDermott Will & Emery
Speakers:
Mindy Herzfeld, Professor of Practice, University of Florida Levin College of Law
Marcus Heyland, Principal, Washington National Tax, KPMG
Alyson Lawrence, Vice President, Global Taxation, Johnson & Johnson

Additional panelist may be added.

Networking Reception

Continental Breakfast

Welcome Back

A Fireside Chat with Manal Corwin, Director, OECD's Centre for Tax Policy and Administration

Facilitated by Danielle Rolfes, Partner in Charge, Washington National Tax, KPMG

A Fireside Chat with Senator Ron Wyden (D-OR), Chairman, Senate Finance Committee

Facilitated by Ryan Abraham, Principal, Washington Council EY

Break

The Present and the Future of GILTI, FDII and BEAT

GILTI, FDII and BEAT were designed to raise revenue while making the United States a more competitive jurisdiction globally, but tax is only one of many factors that businesses must consider in deciding whether to move assets and operations back to the United States. This panel will discuss the impact of the changes to the U.S. tax system on location decisions and what the business community and policymakers can learn from those changes going into 2025. We’ll also consider the potential impact of the changes scheduled to go into effect in 2026, including the potential for double taxation as countries around the world adopt Pillar 2 taxes and U.S. tax on cross-border income increases.

Moderator:
Daniel Winnick, Principal, International Tax Group, KPMG
Speakers:
Nita Asher, Principal, International Tax Services, PwC
Chan Chea, Vice President, Global Head of Tax, Gilead
Daniel Smith, Director, International Tax Planning & Policy, Google
John Stowell, Senior Vice President – Tax, Incentives & International Financial Reporting, Disney

Turning Good Ideas into Good Outcomes: How Taxpayers and Policymakers Can Work Together Effectively to Produce Good Results

This panel will examine issues at the intersection of tax policy and effective advocacy. It will examine successful tax advocacy efforts (both with legislative and regulatory decisionmakers), focusing on efforts that fueled economic growth. Conversely, it will cover examples of tax legislation that went awry, causing confusion and disruption in its wake, and ask whether alternate advocacy methods would have been impactful. The panel will explore best practices and strategies for bridging the gap between real-world tax consequences and the ideas behind legislation.

Moderator:
Barbara Angus, Global Tax Policy Leader, EY
Speakers:
Joseph Novak, Vice President, Taxes, Abbott
Tom Roesser, Tax Policy Counsel, Microsoft
Bob Stack, Managing Director, International Tax Group, Washington National Tax, Deloitte Tax

State and Priorities of the IRS

Remarks by Doug O’Donnell, Deputy Commissioner, Internal Revenue Service

The Chief Tax Officer View: Navigating the Uncertainty and Complexity of the Future

The year 2025 is expected to bring unprecedented challenges and opportunities for tax leaders. With the uncertain tax legislative and regulatory landscape, the rapid changes in AI and technology, the challenges of attracting and developing tax talent, and the growing mandates of tax disclosures, how can tax functions prepare for the future while continuing to deliver value to their organizations and stakeholders?

Several veteran chief tax officers share their perspectives and experiences on leading a tax function into the tax uncertainty of 2025. These topics will include:
• Adapting to the evolving tax landscape and managing the risks and opportunities of major tax policy changes
• Leveraging technology to enhance tax efficiency, effectiveness, and compliance
• Developing and retaining a tax team that can cope with the changing demands and expectations of the business and policymakers
• Communicating the challenges and opportunities for the tax function - to stakeholders, both within and outside the organization

Moderator:
Rema Serafi, Vice Chair – Tax, KPMG
Speakers:
Paul Nolan, Vice President, Tax, Government Affairs & Strategic Real Estate, McCormick & Company
Scarlet Pereira, Executive Vice President, Global Tax, Mastercard
Natalie Rorem, Vice President, Tax, Boeing
Mark Volpe, Senior Vice President, Tax, Regeneron

Closing Remarks