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.
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.
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
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.
Pam Olson, US Deputy Tax Leader & Washington National Tax Services (WNTS) Practice Leader
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.
Will Morris, Deputy Global Tax Leader, PwC
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
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.
Danielle Rolfes, Co-Partner-in-Charge, Washington National Tax – International Tax
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.
Rocco Femia, Member, Miller & Chevalier Chartered
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.
Kevin Levingston, Tax Partner, PwC
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
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.
Madeleine Barber, Senior Vice President and Chief Tax Counsel, CBRE
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
7:30 AM - 8:00 AM
8:00 AM - 8:30 AM
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.
Dave Noren, Partner, McDermott Will & Emery
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
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.
Mary Duffy, Managing Director, Andersen Tax
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.
Jon Traub, Principal in Charge, Tax Policy Group – Washington National Tax, Deloitte Tax LLP
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
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
Congressman Carlos Curbelo
Squire Patton Boggs
Ivins, Phillips & Barker
Tupperware Brands Corporation
Lockheed Martin Corporation
United Technologies Corporation
Martin Marietta Materials Inc.
Skadden Arps Slate Meagher & Flom
Eli Lilly and Company
McDermott Will & Emery
McCormick & Company, Inc.
Exxon Mobil Corporation
Procter & Gamble
The Walt Disney Company
Miller & Chevalier Chartered
Johnson & Johnson
The Boeing Company
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):
- Call 202-835-0500 or 800-241-3333 and reference “2019 TCPI Symposium”
- 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
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 email@example.com. 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 firstname.lastname@example.org.