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Conference

The evolving boundaries of tax

February 14 - 15, 2019

Program Manager: PwC

Program Description.

Recent years have brought dramatic changes to the rules addressing governments’ assertions of taxing jurisdiction over businesses and activities crossing their borders.  Driven in part by politics and media, their efforts reflect concerns about the impact of globalization and digitization on their tax bases and persistent government budget shortfalls at all levels.  Internationally, the OECD’s BEPS project tackled closing the gaps and inconsistencies between countries’ tax laws that provided opportunities for light or non-taxation of corporate income, but left unanswered in which country the income should be taxed.  Many foreign jurisdictions have also considered enactment of a digital services tax on revenue, as they view the current taxing regime is not fit for the digital economy.  U.S. Tax Reform has added uncertainty by raising questions regarding the continuing role of long-standing principles such as the arm’s-length standard, while the Supreme Court abandoned its restraint on states’ imposition of tax obligations on businesses with no physical presence in the state.

Join us at the 20th Annual Tax Policy & Practice Symposium as we consider the rapidly evolving boundaries of tax jurisdiction.  Over our two days together, leaders of the tax community will discuss:

  • The impact of new ideas (BEAT, Digital Services Tax, etc.) on the current state of affairs and future direction of the international tax regime.
  • The current status of implementation of the Tax Cuts and Jobs Act.
    • What guidance has been issued?
    • What guidance is still outstanding?
    • What legislative changes or challenges may arise in the future?
  • Reactions to U.S. Tax Reform from our trading partners, including discussion of potential repercussions; and
  • How governments are reconsidering their right to tax in the face of significant business and economic changes.

Join the dialogue with other tax executives, policymakers, administrators, economists, tax advisors, and academics as we come together to explore emerging policy considerations, share insights, and exchange practical strategies for managing and navigating the evolving boundaries of taxation.

 

Continuing Education.

CPE: TBA
CLE: TBA

The Tax Council Policy Institute is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: http://www.learningmarket.org.

When & Where

February 14 - 15, 2019
Annual Symposium
The Ritz-Carlton
1150 22nd Street NW
Washington, DC, Washington, DC
+ Google Map

Program Manager

PwC

The Agenda.

Day 1

  • 7:00 AM - 8:00 AM

    Continental Breakfast and Registration

  • 8:00 AM - 8:20 AM

    Welcome Remarks and Recognition of Symposium Mission

  • 8:20 AM - 9:00 AM

    Opening Keynote Address

    Speaker: TBA

  • 9:00 AM - 10:00 AM

    International Tax Regime: Shifting Borders and Eroding Boundaries

    To open the Symposium, this panel will provide a high-level overview of governmental actions affecting the taxation of cross-border business activities ranging from the implementation of BEPS to unilateral actions such as the Diverted Profits Tax and digital services taxes to US tax reform. The panel will explore what the various governmental actions mean for the stability of the international tax regime, risks of excess taxation, and future direction; as well as the import of destination-based features of recent tax changes, including the Tax Cuts and Jobs Act. The panel will consider whether the enactment of US tax reform is the final step or, together with proposals for market-based intangibles, digital PEs, and retreats from the arms’-length standard, merely the next step in reconsideration of the international tax regime.

    Moderator:
    Pam Olson, US Deputy Tax Leader & Washington National Tax Services (WNTS) Practice Leader
    Panelists:
    Barbara Angus, Former Chief Tax Counsel, House Committee on Ways and Means
    Chip Harter, Deputy Assistant Secretary (International Tax Affairs), U.S. Department of the Treasury
    Paul Nolan, Vice President – Tax & Government Affairs, McCormick & Company, Inc.
    Vicki Perry, Division Chief, International Monetary Fund

  • 10:00 AM - 11:00 AM

    Impact of Globalization and Digitalization on Taxes

    The OECD returned to analyzing the impact of digitalization and globalization on the international tax rules and divisions among OECD members on the existence and scope of the issue. The OECD’s digital tax working group identified three different country views regarding taxation of the digital economy: (1) no change required, (2) change required for digital companies only, and (3) change of the international tax rules may be required to reflect economic changes stemming from globalization and digitization. The panel will explore what is driving the debate, the options under consideration, the prospect for consensus, and the impact of the US Supreme Court’s analysis in Wayfair on the debate.

    Moderator:
    Will Morris, Deputy Global Tax Leader, PwC
    Panelists:
    Tim Berger, Executive Vice President – Global Tax, MasterCard
    Mindy Herzfeld, Of Counsel, Ivins, Phillips & Barker
    Brian Jenn, Deputy International Tax Counsel, U.S. Department of the Treasury
    Paul Oosterhuis, Of Counsel, Skadden, Arps, Slate, Meagher & Flom LLP

  • 11:00 AM - 11:30 AM

    Break

  • 11:30 AM - 12:30 PM

    GILTI & FDII Implementation: Lessons Learned

    The first of three panels exploring the TCJA international tax regime will focus on GILTI and FDII. The panel will discuss the policy intentions behind these provisions and whether they appear to be achieving their design goal and whether the provisions are in violation of international rules. The panel will also address issues in this area that are top of mind for many tax directors such as expense allocation and definition of foreign use, and whether the group anticipates further changes or clarifications as the regulations move towards finalization.

    Moderator:
    Danielle Rolfes, Co-Partner-in-Charge, Washington National Tax – International Tax
    Panelists:
    Jackie Crouse, Vice President, Taxes, Amgen Inc.
    Holly Goughnour, Vice President, Tax, International Paper
    Jose Murillo, Leader, International Tax Services, EY
    Gary Scanlon, Attorney-Advisor, Office of the International Tax Counsel, U.S. Department of the Treasury
    Chris Wolter, Vice President, Tax, The Boeing Company

  • 12:30 PM - 2:00 PM

    Luncheon and Pillar of Excellence Award presentation

    Award Recipient: TBA

  • 2:00 PM - 3:00 PM

    We got the BEAT… and now what do we do?

    The second panel exploring the TCJA international tax regime will focus on the BEAT, a minimum tax with a destination-based focus. The panel will address the expected and unexpected complexities raised by the BEAT, how taxpayers are addressing these complexities and impacts, the current state of the guidance, and where we go from here.

    Moderator:
    Rocco Femia, Member, Miller & Chevalier Chartered
    Panelists:
    John Misso, Senior Tax Counsel; Senior Manager, Tax Policy Americas, Shell Oil Company
    Kevin Nichols, Senior Counsel, Office of the International Tax Counsel, U.S. Department of the Treasury
    Mark Prater, Managing Director, Tax Policy Services, PwC
    Tim Wright, Vice President, Tax Planning & International Tax, FedEx

  • 3:00 PM - 3:45 PM

    Trust, but Model

    The final panel discussing TCJA implementation will focus on the interactions between and modeling of the various provisions. The panel will discuss how the new provisions come together and impact one another, but also go a step further and consider how these provisions interact with long-standing rules, such as transfer pricing norms. The panel will also discuss what items are still unresolved in their models and how they have approached communicating results to senior management and audit committees.

    Moderator:
    Kevin Levingston, Tax Partner, PwC
    Panelists:
    Melissa Hall, Senior Vice President, Tax, Assurant Inc.
    Brian Krause, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
    Katie Lodato, Vice President – Global Tax, Eli Lilly and Company

  • 3:45 PM - 4:15 PM

    Break

  • 4:15 PM - 5:30 PM

    Foreign Government Response: Fight or “Capital” Flight

    The enactment of US tax reform dramatically shifted the international tax playing field. In this session, the panel will consider the responses (actual and potential) of foreign governments to US tax reform, including review of FDII by the OECD’s forum on harmful tax practices, potential WTO challenges, consistency with tax treaty provisions, and potential retaliatory taxes. The panel will also discuss the viability of challenges and claims, the timetables for consideration, and potential US responses. Finally, this panel will consider tax trends in the EU, including the future of digital services tax in Europe and globally, as well as the implications of a digital tax on sectors beyond its high-tech targets. Finally, the group will discuss the prospects for replacement of any interim measure with the CCCTB and implications of a CCTP for taxation of global enterprises.

    Moderator:
    Madeleine Barber, Senior Vice President and Chief Tax Counsel, CBRE
    Panelists:
    Grant Aldonas, Principal Managing Director, Split Rock International
    Manal Corwin, Principal-in-Charge, Washington National Tax, KPMG
    Sandy Radmanesh, Senior Tax Counsel, German Embassy Washington, DC
    Tom Roesser, Senior Director, Tax Affairs, Microsoft
    Bob Stack, Managing Director, International Tax Group – Washington National Tax, Deloitte Tax LLP

  • 5:30 PM - 7:00 PM

    Networking Reception

Day 2

  • 7:30 AM - 8:00 AM

    Continental Breakfast

  • 8:00 AM - 8:30 AM

    Keynote Address

    Speaker: TBA

  • 8:30 AM - 10:00 AM

    Arm’s Length Standard: Have the rumors of its death been greatly exaggerated?

    While pledging loyalty to the arm’s-length standard, the DPT, BEAT, digital services tax proposals, and recent judicial decisions signal government discomfort with its administrability and operation. This panel will discuss the future of arm’s length standard, what will it take to preserve it, and replacement options.

    Moderator:
    Dave Noren, Partner, McDermott Will & Emery
    Panelists:
    Tadd Fowler, Vice President – Global Tax Operations, Procter & Gamble
    Itai Grinberg, Professor of Law, Georgetown Law
    Mike McDonald, Executive Director, Transfer Pricing Services, National Tax Department, EY
    Jeff VanderWolk, Partner, Squire Patton Boggs

  • 10:00 AM - 10:30 AM

    Break

  • 10:30 AM - 11:30 AM

    Wayfair: The Supreme Court provides a roadmap, where might the world go?

    The Supreme Court handed down its Wayfair decision striking down decades-long precedent preventing states from requiring businesses without physical presence in the state to collect taxes on sales to customers in the state. This session will examine both practical issues and the broader implications of the Supreme Court’s recognition of virtual presence as sufficient for permitting states to require sales tax collection, including potential activity of the states, Congress and even foreign governments.

    Moderator:
    Mary Duffy, Managing Director, Andersen Tax
    Panelists:
    Don Griswold, Co-Leader, SALT Team – Insourced Solutions for Tax (IST), PwC
    Doug Lindholm, President & Executive Director, Council On State Taxation
    Eric Oman, Deputy Chief Tax Policy Advisor, Senate Finance Committee
    Joel Walters, Director, Department of Revenue, State of Missouri

  • 11:30 AM - 12:30 PM

    Money makes the world go around

    Globally, governments continue to search for new or additional ways to increase tax revenues. Fiscal challenges present in many countries around the globe have resulted in politicians looking to expanding or new tax bases to bridge the gap. This panel will discuss viable options for increasing government revenue and how politics affect proposals to tax multinational corporations and their extraterritorial actions.

    Moderator:
    Jon Traub, Principal in Charge, Tax Policy Group – Washington National Tax, Deloitte Tax LLP
    Panelists:
    Beth Bell, Policy Director and Tax Counsel, Senate Committee on Small Business & Entrepreneurship
    Congressman Carlos Curbelo
    Jon Lieber, Principal, NES Practice, PwC
    Maya MacGuineas, President, Committee for a Responsible Federal Budget

  • 12:30 PM - 12:45 PM

    Wrap up

Tickets.

  • Early Bird Registration (Register by COB January 18, 2019) - $885.00
  • Select Number of Tickets
    -1 available
    Regular Registration$985.00 per ticketRegister after COB January 18, 2019

    Please fill in all required fields

    -1 available
    Government employees and Academia (full-time faculty and students)$300.00 per ticket

    Please fill in all required fields

    -1 available
    Speaker Registration$0.00 per ticket

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    -1 available
    Exhibitor Registration$0.00 per ticket

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    -1 available
    Media Registration$0.00 per ticket

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    If you would like to pay with a check, please fill out this form and send it with the check to:

    Tax Council Policy Institute
    600 13th Street NW, Suite 1000
    Washington, DC 20005

    The Speakers.

    Grant Aldonas

    Principal Managing Director
    Split Rock International
    Barbara Angus

    Barbara Angus

    Former Chief Tax Counsel
    House Committee on Ways and Means

    Madeleine Barber

    Senior Vice President and Chief Tax Officer
    CBRE

    Beth Bell

    Policy Director and Tax Counsel
    Senate Committee on Small Business & Entrepreneurship

    Tim Berger

    Executive Vice President - Global Tax
    MasterCard
    corwin

    Manal Corwin

    Principal-in-Charge, Washington National Tax
    KPMG

    Jacqueline Crouse

    Vice President, Taxes
    Amgen Inc.

    Congressman Carlos Curbelo

    Mary Duffy

    Managing Director
    Andersen Tax

    Rocco Femia

    Member
    Miller & Chevalier Chartered

    Tadd Fowler

    Vice President - Global Tax Operations
    Procter & Gamble

    Holly Goughnour

    Vice President, Tax
    International Paper

    Itai Grinberg

    Professor of Law
    Georgetown Law

    Don Griswold

    Co-Leader, SALT Team - Insourced Solutions for Tax (IST)
    PwC

    Melissa Hall

    Senior Vice President, Tax
    Assurant Inc.

    Chip Harter

    Deputy Assistant Secretary (International Tax Affairs)
    U.S. Department of the Treasury

    Mindy Herzfeld

    Of Counsel
    Ivins, Phillips & Barker

    Brian Jenn

    Deputy International Tax Counsel
    U.S. Department of the Treasury

    Brian Krause

    Partner
    Skadden, Arps, Slate, Meagher & Flom LLP

    Kevin Levingston

    Tax Partner
    PwC

    Jon Lieber

    Principal, NES Practice
    PwC

    Doug Lindholm

    President & Executive Director
    Council On State Taxation

    Katie Lodato

    Vice President - Global Tax
    Eli Lilly and Company

    Maya MacGuineas

    President
    Committee for a Responsible Federal Budget

    Mike McDonald

    Executive Director, Transfer Pricing Services, National Tax Department
    EY

    John Misso

    Senior Tax Counsel; Senior Manager, Tax Policy Americas
    Shell Oil Company

    William Morris

    Deputy Global Tax Policy Leader
    PwC

    Jose Murillo

    Leader, International Tax Services
    EY

    Kevin Nichols

    Senior Counsel, Office of the International Tax Counsel
    U.S. Department of the Treasury

    Paul Nolan

    Vice President - Tax & Government Affairs
    McCormick & Company, Inc.

    David Noren

    Partner
    McDermott Will & Emery

    Pam Olson

    US Deputy Tax Leader & Washington National Tax Services (WNTS) Practice Leader
    PwC

    Eric Oman

    Deputy Chief Tax Policy Advisor
    Senate Finance Committee

    Paul Oosterhuis

    Of Counsel, International Tax
    Skadden, Arps, Slate, Meagher & Flom LLP

    Vicki Perry

    Division Chief
    International Monetary Fund

    Mark Prater

    Managing Director, Tax Policy Services
    PwC

    Sandy Radmanesh

    Senior Tax Counsel
    German Embassy Washington, DC

    Tom Roesser

    Senior Director, Tax Affairs
    Microsoft

    Danielle Rolfes

    Co-Partner-in-Charge, Washington National Tax - International Tax
    KPMG

    Gary Scanlon

    Attorney-Advisor, Office of the International Tax Counsel
    U.S. Department of the Treasury

    Jonathan Traub

    Principal in Charge, Tax Policy Group - Washington National Tax
    Deloitte Tax LLP

    Robert Stack

    Managing Director, International Tax Group - Washington National Tax
    Deloitte Tax LLP

    Jefferson VanderWolk

    Partner
    Squire Patton Boggs

    Joel Walters

    Director, Department of Revenue
    State of Missouri

    Christopher Wolter

    Vice President, Tax
    The Boeing Company

    Tim Wright

    Vice President, Tax Planning & International Tax
    FedEx

    Planning Committee.

    CBRE

    Madeleine Barber
    Senior Vice President & Chief Tax Officer

    Loews Corporation

    Susan Becker
    Vice President, Chief Tax Officer

    MasterCard

    Timothy Berger
    Executive Vice President - Tax

    FedEx

    Robert L. Brown
    Corporate Vice President Tax

    PepsiCo, Inc.

    Jeffrey J. Coniaris
    Senior Vice President, Tax Planning

    AmerisourceBergen

    Kevin Conway
    Senior Vice President, Tax

    Amgen

    Jacqueline Crouse
    Vice President, Tax

    Squire Patton Boggs

    Matthew Cutts
    Partner
    Program Manager Advisory Committee

    Hess Corporation

    C. Martin Dunagin
    Vice President, Corporate Tax

    Deloitte Tax

    Banks Edwards
    Managing Partner, Washington National Tax
    Program Manager Advisory Committee

    Mars, Incorporated

    Anthony Gedeller
    Global Tax & Currency Director

    KPMG

    John Gimigliano
    Principal-in-Charge, Federal Legislative and Regulatory Services
    Program Manager Advisory Committee

    Ivins, Phillips & Barker

    Hank Gutman
    Of Counsel
    Program Manager Advisory Committee

    Tupperware Brands Corporation

    Josef Hajek
    Senior Vice President, Tax & Government Affairs

    Assurant Inc.

    Melissa Hall
    Senior Vice President - Tax

    Intel Corporation

    Sharon Heck
    Vice President, Finance and Global Tax

    Lockheed Martin Corporation

    David A. Heywood
    Vice President, Taxes & General Tax Counsel

    United Technologies Corporation

    Ross Kearney
    Corporate Vice President, Tax

    Martin Marietta Materials Inc.

    Pam Kelly
    Vice President, Corporate Tax

    Skadden Arps Slate Meagher & Flom

    Brian Krause
    Partner
    Program Manager Advisory Committee

    Masco Corporation

    Lawrence Leaman
    Vice President - Global Taxes

    Eli Lilly and Company

    Katie Lodato
    Vice President, Global Tax

    Anderson Tax

    Ellen MacNeil
    Managing Director
    Program Manager Advisory Committee

    International Paper

    Kevin McWilliams
    Vice President Tax

    T-Mobile

    Chris Miller
    Vice President, Tax

    McDermott Will & Emery

    David Noren
    Partner
    Program Manager Advisory Committee

    McCormick & Company, Inc.

    Paul Nolan
    Vice President, Tax & Government Affairs

    PwC

    Pam Olson
    US Deputy Tax Leader and Washington National Tax Services (WNTS) Practice Leader
    Program Manager

    Exxon Mobil Corporation

    Tim Raymond
    General Tax Counsel - Downstream

    AbbVie

    Scott Reents
    Vice President, Tax

    Procter & Gamble

    Amy Roberti
    Director, US Federal Government Relations Leader and Global Tax Policy

    Microsoft

    Thomas Roesser
    Senior Director - Tax Affairs

    Citigroup

    Saul Rosen
    Senior Tax Counsel and Managing Director

    EY

    Eric Solomon
    Co-Director, National Tax
    Program Manager Advisory Committee

    The Walt Disney Company

    John Stowell
    Senior Vice President, Corporate Tax

    Miller & Chevalier Chartered

    Patricia Sweeney
    Member
    Program Manager Advisory Committee

    Deloitte Tax

    Jonathan Traub
    Managing Principal, Tax Policy Group
    Program Manager Advisory Committee

    Johnson & Johnson

    Louise Weingrod
    Vice President, Global Taxation

    Caterpillar Inc.

    Chad Withers
    Global Tax Director & Chief Tax Officer

    The Boeing Company

    Christopher Wolter
    Vice President, Taxes

    Hotel Information.

    Where:

    The Ritz-Carlton Washington DC
    1150 22nd Street NW
    Washington, DC 20036
    +1 202 835 0500

    Rate for Feb. 13 and 14**:

    $355 per night plus tax and fee

    Reservation Method (choose one):

    1. Call 202-835-0500 or 800-241-3333 and reference “2019 TCPI Symposium”
    2. Reserve online – click here

    All reservations should be received by no later than Wednesday, January 23, 2019.  After this date, room availability and pricing cannot be guaranteed.

    ** There is a limited number of rooms available three days prior to and three days after the conference dates.  If you would like to add to your stay, please contact Marcia Gomes at Marcia.Gomes@ritzcarlton.com.

    Check-in and Check-out

    • Check in: 3:00 PM
    • Check out: 12:00 PM

    Room Cancellation Policy:

    72 hours prior to arrival

    Additional Information.

    Who should attend?

    The program is designed for CFOs, VPs of Tax, VPs of Finance, corporate tax directors, government tax professionals, tax counsels, attorneys, and managers. The method of delivery will be group-live at an intermediate to advanced level. Participants should possess an advanced knowledge of tax policy and practice.

    Does the registration cost include hotel reservation?

    No. You must make your own hotel reservation. A limited number of rooms has been put on hold at The Ritz-Carlton Washington DC (1150 22nd Street NW) for the evenings of Feb 13th and 14th for $355 per night (plus tax and fees). Check out the "Hotel" section for additional information.

    Can I obtain continuing education credits (CLE or CPE) by attending this conference?

    Participation in the Symposium will allow you the opportunity to receive continuing education credits. TCPI is registered with NASBA, and in accordance with its policies, up to 12 CPE credits can be earned. (NASBA Field of Study: TAXATION.) TCPI will also apply for CLE accreditation post-conference from those states that require it, which participants list on their registration forms. The total amount of earned CLE credits varies by states.

    How do I become an exhibitor?

    To obtain a copy of the exhibitor prospectus, which includes the pricing and benefits of becoming an exhibitor, please email us at general@tcpi.org. Note that spots are limited and we do sell out!

    Should I bring a laptop/tablet computer to this conference?

    Up to you. All conference materials, including the agenda, speaker bios and PowerPoint presentations, will be made available on the password-protected TCPI Symposium website (accessible to attendees only). There will be wifi and writing surface available in the conference room. In the past, some attendees have chosen to bring their laptops/tablet computers to the conference or print everything out beforehand.

    What is the cancellation and refund policy?

    Fees are refundable, less a $100 processing fee, if written notice is received by TCPI prior to COB Friday, January 18, 2019. There will be no refunds after January 18, 2019; however, a substitute for the original registrant will be accepted. For more information regarding registration, refund, complaint, and/or program cancellation policies, please call TCPI at (202) 822-8062 or email symposium@tcpi.org.

    Join us for an amazing event full of industry insights and knowledge.

    REGISTER NOW >
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