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Conference

Hindsight is 2020: What the TCJA and Global Developments Tell Us About the Future of Tax

February 13 - 14, 2020

Program Manager: KPMG

Updates.

(12/11/19)  Press Release: “TCPI’s 21st Annual Symposium to Explore U.S. Tax Reform, Global Developments, and Future of Tax

Program Description.

After years of effort, Congress finally enacted comprehensive tax reform in late 2017.  With Congress’s work done, the tax community then began the complex process of implementing the new domestic and international business tax system.

But, a lot has happened since 2017.  Plus, history tells us that the tax law is never “done” — it’s always evolving.  It evolves in response to both internal forces (such as economic and political developments, differing points of view and priorities, and other pressures within the United States) and external forces (such as tax, trade, economic, and political developments outside the United States).  Indeed, the current drive by some OECD countries to make massive changes to fundamental principles of business taxation seems virtually unprecedented and is moving at a surprisingly fast pace.

So even as the United States continues to work to put its new regime into place, internal and external forces might compel even more changes to the U.S. tax system in the new decade — possibly further shifting the landscape for both domestic and multinational businesses.

To evaluate and to anticipate these possible changes, they must be identified and evaluated relative to current law — that is, do they make the tax system better or worse, do they raise or lose revenue, and so on.

The 2020 program will review the current state of the U.S. tax law, as substantially modified by the 2017 tax reform legislation.  The internal and external pressures on the tax system will be examined to assess whether the policy choices reflected in the current Tax Code are still the right ones today, especially with regard to the taxation of domestic and multinational businesses.

In other words, the program will ask the question: what policy changes could, or should, be explored based upon what we know now about the functioning of the substantially modified U.S. tax system, given both recent worldwide developments and our two years of experience so far with the new U.S. tax rules?

After all, hindsight is “2020.”

Join business, government, and academic leaders at the 21st Annual Tax Policy & Practice Symposium as we consider how the U.S. tax system might evolve in response to internal and external forces.  Below are just a few of the critical topics that leaders of the tax community will explore over our two days together.

  • What are the real world effects of the TCJA and how has it changed thinking about global investment?
  • Innovation — does the new U.S. tax system strike the right balance to encourage high value activity in the United States?
  • How does the new interest deduction limitation (and the even lower “cap” scheduled to go in effect in 2022) change financing decisions and structures?
  • What’s the state of play of the OECD’s efforts to reform international tax standards — what’s really motivating these efforts and how might actions by other countries drive changes to U.S. tax policy?
  • With two years of experience, how are the GILTI rules working relative to other anti-base erosion proposals?
  • What might some of the significant changes to the U.S. system that have recently been proposed mean for the future of domestic and multinational tax?

 

The program also will introduce new features to make the Symposium particularly engaging and relevant — including expanded use of technology, as well as “mini-sessions” with lively debates on topical issues interspersed with more in-depth discussions.  Breakout sessions — with separate tracks for domestic, international, policy, and technical issues — will also drill down into key issues of interest to tax executives, practitioners, policy makers, advisers, and all others concerned with the tax policy process.

 

Continuing Education.

CPE: To be determined
CLE: To be determined

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.nasbaregistry.org/.

When & Where

February 13 - 14, 2020
Annual Symposium
The Ritz-Carlton
1150 22nd Street NW
Washington, DC, Washington, DC

Program Manager

KPMG

The Agenda.

Day 1

  • 7:00 am - 7:45 am

    Continental Breakfast and Registration

  • 7:45 am - 8:00 am

    Welcome Remarks and Recognition of Symposium Mission

  • 8:00 am - 8:30 am

    Opening Keynote Address

    Speaker TBA

  • 8:30 am - 8:45 am

    Opening Video: The Case for TCJA

  • 8:45 am - 9:15 am

    CBO Outlook

    The U.S. is hard at work implementing a new tax regime. But more changes may soon be in store. Phillip Swagel, Director of the Congressional Budget Office, will examine economic forces that are poised to shape the U.S. budgetary outlook – including both spending commitments and revenue sources.

    Speaker:
    Phillip Swagel, Director, Congressional Budget Office

  • 9:15 am - 10:00 am

    The Economists’ View

    Enacting comprehensive tax reform in 2017 marked a monumental change to the U.S. tax system. Now, two years in, we can begin to understand its broad economic impact. Join a panel of experienced economists as they offer their views on how new U.S. tax rules have affected business financing, structuring investment, innovation, trade, and other aspects of the U.S. economy.

  • 10:00 am - 10:15 am

    Mini-Session: Corporate Rate Point/Counterpoint

    One of the most significant provisions of the TCJA is the cutting of the U.S. corporate income tax rate. It is also one of the most intensely debated. Is 21% the right rate for a healthy business environment? What were the intended goals of the rate cut and are those goals being achieved? The session provides a brief point-counterpoint on this “tent-pole” aspect of the TCJA.

  • 10:15 am - 11:00 am

    The TCJA in Action: Tax Reform in the Real World

    Part of the promise of the TCJA, as set forth in the Unified Framework on tax reform, was “to make America the jobs magnet of the world by leveling the playing field for American businesses.” Two years on from enactment, can we begin to evaluate to what extent and how the new law achieves these goals? This panel of senior tax executives will discuss the real-world effects of the most fundamental aspects of U.S. tax reform on American businesses and workers, including the lower corporate tax rate, the participation exemption system, GILTI, and more.

  • 11:00 am - 11:30 am

    Break

  • 11:30 am - 12:15 pm

    From Hindsight to Insight: Assessing Tax Reform’s Effect on Innovation and other High-Value Activity

    From R&D and scientific discovery to technology commercialization, spurring American innovation was a major goal of the TCJA. This panel will assess those elements of U.S. tax reform - including the FDII deduction, the BEAT, and the capitalization of Section 174 expenses - that were designed, either directly or indirectly, to incentivize and support innovation. The panel will also evaluate the global state of play concerning innovation and brainstorm how America might enhance its environment for innovation through future tax changes.

  • 12:15 pm - 2:00 pm

    Luncheon and Pillar of Excellence Award Presentation

    Pillar of Excellence Award Recipient TBA

  • 2:00 pm - 2:50 pm

    Breakout Sessions:

    1. Survival Mode: Staying Afloat in the Wake of the Flood of TCJA Domestic Tax Guidance [domestic track - technical]

    Enactment of the TCJA marked a new dawn for the U.S. tax system. But for domestic tax compliance leaders, it was just the first of countless changes to come - and to somehow manage. Post-tax reform, U.S. regulators issued technical guidance at an unprecedented pace, with each new development posing a new implementation challenge. This panel will explore real-world survival stories from the 2018 compliance season, when most guidance was either not available or still in proposed form. It will also look ahead to the next filing season, offering tax compliance leaders practical options for handling continued uncertainty regarding key provisions such as cost recovery, income recognition, and the interest limitation.


    2. Will Non-OECD Nations Push the US Toward a Destination-Based Tax System? [international track - policy]

    Many developing countries impose destination-based tax systems. As their share of global GDP increases, their consumer markets grow, and they attract more foreign investment, what challenges do these tax regimes present for multinational corporations doing business within their borders? Are destination-based tax systems sustainable in today’s global economy - and will the U.S. ever seriously consider such a system? This session will explore these fundamental questions about the future of international tax and its impact on the U.S. business community.

  • 3:00 pm - 3:50 pm

    Breakout Sessions:

    1. Transfer Pricing: Developments and the Path Forward [international track – technical]

    Recent developments at home and abroad, including the enactment of several new international provisions under the TCJA and the OECD’s ongoing work addressing novel nexus and profit allocation issues presented by the digitalization of the economy, are making the management of transfer pricing challenges even more complex. This panel of senior tax executives and transfer pricing experts will take an in-depth look at transfer pricing through the lens of these developments, and answer key questions including: What tensions exists between the well-established transfer pricing rules under section 482 and the inbound anti-base erosion measure codified under section 59A? What are the recent trends in transfer pricing litigation? Is the arm’s length standard dead, and if so, what are the alternatives in today’s constantly changing global economy?


    2. The Future Role of the Corporate Income Tax [domestic track – policy]

    The TCJA was seen as one of the largest overhauls of the U.S. tax code ever. And the new, lower corporate rate was considered by many to be the most significant change. This panel will explore the real-world impact of business tax changes under the TCJA and what they might mean for domestic tax policy in future - particularly if a separate tax on corporate income will still be relevant in America’s changing economic and political climate.

  • 3:50 pm - 4:20 pm

    Break

  • 4:20 pm - 5:15 pm

    Debating Debt: What’s the Real Deal with the Interest Limitation?

    Since the TCJA was enacted, taxpayers have been consumed with a host of technical questions about how the new limit on the deductibility of business debt applies. But there’s a bigger question: Do the new rules really reverse the tax code’s preferential treatment of debt and tip the scales toward equity? The panel will address how the new limitation is affecting C-suite decisions and business behavior, what its real-world impact is shaking out to be, and how the scheduled future change to the limitation might affect the tax landscape.

  • 5:15 pm - 5:30 pm

    Day-end Recap

  • 5:30 pm - 7:00 pm

    Networking Reception

Day 2

  • 7:30 am - 8:15 am

    Continental Breakfast

  • 8:15 am - 8:30 am

    Welcome Back

  • 8:30 am - 9:00 am

    Video: The OECD speaks

  • 9:00 am - 10:00 am

    Grappling with Global Reform

    The OECD continues to push toward a global solution to address the tax challenges presented by the digital economy. The specter of major changes to the international tax system looms large, yet nothing is certain - even whether consensus will be reached. However the OECD’s work unfolds, businesses will need to adapt and react. This panel will help multinational businesses manage the uncertainty of this moment with insights on the latest OECD proposals and practical discussion on how to navigate the current fluid state of international tax rules.

  • 10:00 am - 10:15 am

    Mini-Session: Weighing Unilateral Options Available to the U.S.

    As the OECD seeks a global solution on digital taxation, single jurisdictions are pursuing unilateral actions, creating great complexity for multinational businesses. This mini-session will debate the possible responses available to U.S. policymakers. Is doubling the tax rate on other countries under section 891 a real option? Are there other tax measures available? Or is trade the most likely retaliatory tool?

  • 10:15 am - 10:45 am

    Break

  • 10:45 am - 11:00 am

    Mini-Session: What is the Goal of the Tax System?

    Is the view that corporations should pay “fairer share” of tax a driving factor in the OECD’s international tax system reform work? When you really get down to it, are the issues at hand economic ones, ideological ones, or something else? Join a lively discussion of whether the tax morality debate raging around the world is based on policy or politics.

  • 11:00 am - 11:50 am

    Case Erosion: GILTI, Minimum Taxes and the Future of Outbound Taxation Post U.S. Tax Reform

    The GILTI was designed as the principal outbound anti-base erosion measure of the new U.S. international tax system. Does the provision hit the mark? This panel will examine the design of the GILTI regime, its interaction with BEAT, the key issues it raises for U.S.-based multinationals, and practical considerations for corporations adapting to the new law. Hear analysis of complex questions, including: Has the GILTI regime succeeded in preventing outbound base erosion? How have policy decisions by U.S. authorities influenced its effectiveness? What alternatives have been proposed by domestic and international policymakers and what impact would they have on taxpayers in different industries?

  • 11:50 am - 12:30 pm

    20/20 Vision – Looking Ahead to the 2020 Elections and Beyond

    Experts will draw from their tax, economic and governmental expertise to focus upon what impact the results of the 2020 presidential and congressional elections could have upon the tax world. Panelists will discuss various tax proposals from both Democrats and Republicans and focus on the future in a post-2020 Washington.

  • 12:30 pm - 12:45 pm

    Closing Remarks

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  • Early Bird Registration (Register by COB January 17, 2020) - $950.00
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    -1 available
    Government employees and Academia (full-time faculty and students)$350.00 per ticket

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    The Speakers.

    Michael Desmond

    Chief Counsel
    Internal Revenue Service

    Grace Perez-Navarro

    Deputy Director, Centre for Tax Policy and Administration
    Organisation for Economic Cooperation and Development

    Pascal Saint-Amans

    Director, Centre for Tax Policy and Administration
    Organisation for Economic Cooperation and Development

    Phillip Swagel

    Director
    Congressional Budget Office

    Jennifer Acuña

    Principal, Federal Legislative and Regulatory Services
    KPMG

    Rosanne Altshuler

    Professor of Economics
    Rutgers University

    Barbara Angus

    Global Tax Policy Leader
    EY

    Madeleine Barber

    Senior Vice President & Chief Tax Officer
    CBRE

    John Bates

    Principal, Washington National Tax
    Deloitte Tax LLP

    Beth Bell

    Tax Counsel
    House Committee on Ways and Means

    Patrick Brown

    US International Tax Policy Leader
    PwC

    George Callas

    Managing Director, Government Affairs & Public Policy
    Steptoe & Johnson

    Robert Carroll

    Co-director, Quantitative Economics & Statistics Group (QUEST)
    EY

    Kevin Conway

    Senior Vice President, Tax
    AmerisourceBergen

    Jacqueline Crouse

    Vice President, Tax
    Amgen, Inc.

    Heather Crowder

    General Tax Officer
    Phillips 66

    Ronald Dabrowski

    Principal and Technical Deputy, Washington National Tax
    KPMG

    Tadd Fowler

    Vice President – Treasury, Assistant Treasurer, and Global Tax Operations
    Procter & Gamble

    Anthony Gedeller

    Global Tax & Currency Director
    Mars, Incorporated

    Itai Grinberg

    Professor of Law
    Georgetown Law

    Harry L. Gutman

    Of Counsel
    Ivins, Phillips & Barker

    Melissa Hall

    Senior Vice President - Tax
    Assurant Inc.

    Heather Harman

    Managing Director
    Andersen

    Cory Hillier

    Senior Counsel (Tax Law)
    International Monetary Fund

    Shahira Knight

    Principal
    Deloitte

    Mark Mazur

    Robert C. Pozen Director
    Tax Policy Center

    William Morris

    Chair, Business at OECD Taxation Committee
    Deputy Global Tax Policy Leader, PwC

    Paul Nolan

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

    David Noren

    Partner
    McDermott Will & Emery

    Josh Odintz

    Partner
    Baker McKenzie

    Scarlet Pereira

    Interim Head of Tax
    MasterCard

    Kyle Pomerleau

    Resident Fellow
    American Enterprise Institute

    Loren Ponds

    Member
    Miller & Chevalier Chartered

    Danielle Rolfes

    Partner, Co-lead International Tax, Washington National Tax
    KPMG

    Saul Rosen

    Senior Tax Counsel and Managing Director
    Citigroup

    John Stowell

    Senior Vice President, Corporate Taxes
    The Walt Disney Company

    Martin A. Sullivan

    Chief Economist
    Tax Analysts

    Russell Sullivan

    Shareholder
    Brownstein Hyatt Farber & Schreck

    Mitch Thompson

    Partner
    Squire Patton Boggs

    Alan D. Viard

    Resident Scholar
    American Enterprise Institute

    Brett Weaver

    Partner, National Leader, Value Chain Management
    KPMG

    Louise Weingrod

    Vice President, Global Taxation
    Johnson & Johnson

    Tom West

    Principal, Passthroughs Group
    KPMG

    B. Chase Wink

    Partner, Tax
    Skadden, Arps, Slate, Meagher & Flom LLP

    Christopher Wolter

    Vice President, Taxes
    The Boeing Company

    Planning Committee.

    AbbVie

    Scott Reents
    Vice President, Tax and Treasury

    AmerisourceBergen

    Kevin Conway
    Senior Vice President, Tax

    Amgen Inc.

    Jacqueline Crouse
    Vice President, Tax

    Andersen

    Ellen MacNeil
    Managing Director
    Program Manager Advisory Committee

    Assurant Inc.

    Melissa Hall
    Senior Vice President - Tax

    Boeing Company, The

    Christopher Wolter
    Vice President, Taxes

    Brownstein Hyatt Farber Schreck

    Russ Sullivan
    Shareholder
    Program Manager Advisory Committee

    Carlyle Group, The

    Shannon Stafford
    Managing Director

    Caterpillar Inc.

    Chad Withers
    Chief Tax Officer

    CBRE

    Madeleine Barber
    Senior Vice President & Chief Tax Officer

    Citigroup

    Saul Rosen
    Senior Tax Counsel and Managing Director

    Deloitte Tax LLP

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

    Eli Lilly and Company

    Katie Lodato
    Vice President, Global Tax

    EY

    Barbara Angus
    Global Tax Policy Leader
    Program Manager Advisory Committee

    Facebook

    Alan Lee
    Head of Global Tax Policy

    FedEx

    Robert L. Brown
    Corporate Vice President Tax

    Ford Motor Company

    Ron Lang
    Chief Tax Officer

    Intel Corporation

    Sharon Heck
    Corporate Vice President, Treasurer and Chief Tax Officer

    Ivins, Phillips & Barker

    Hank Gutman
    Of Counsel
    Program Manager Advisory Committee

    Johnson & Johnson

    Louise Weingrod
    Vice President, Global Taxation

    KPMG

    Manal Corwin
    Principal in Charge, Washington National Tax
    Program Manager

    KPMG

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

    Lockheed Martin Corporation

    Urvi Doshi Sood
    Vice President, Taxes & General Tax Counsel

    Loews Corporation

    Susan Becker
    Vice President, Chief Tax Officer

    Mars, Incorporated

    Anthony Gedeller
    Global Tax & Currency Director

    Martin Marietta Materials Inc.

    Pam Kelly
    Vice President, Corporate Tax

    Masco Corporation

    Lawrence Leaman
    Vice President - Global Taxes

    MasterCard Worldwide

    Scarlet Pereira
    Interim Head of Tax

    McCormick & Company, Inc.

    Paul Nolan
    Vice President, Tax & Government Affairs

    McDermott Will & Emery

    David Noren
    Partner
    Program Manager Advisory Committee

    Microsoft Corporation

    Thomas Roesser
    Senior Director - Tax Affairs

    Miller & Chevalier Chartered

    Patricia Sweeney
    Member
    Program Manager Advisory Committee

    PepsiCo, Inc.

    Jeffrey Coniaris
    Senior Vice President, Tax Planning

    Phillips 66

    Heather Crowder
    General Tax Officer

    Procter & Gamble

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

    PwC

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

    Skadden Arps Slate Meagher & Flom

    Armando Gomez
    Partner
    Program Manager Advisory Committee

    Squire Patton Boggs

    Matthew Cutts
    Partner
    Program Manager Advisory Committee

    Steptoe & Johnson

    Eric Solomon
    Partner
    Program Manager Advisory Committee

    T-Mobile

    Chris Miller
    Senior Vice President, Tax

    Uber

    Francois Chadwick
    Vice President, Tax & Accounting

    United Technologies Corporation

    Ross Kearney
    Corporate Vice President, Tax

    Walt Disney Company, The

    John Stowell
    Senior Vice President, Corporate Tax

    Hotel Information.

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

    $355 per night plus tax and fee

    Reservation Method (choose one):

    1. Call 202-835-0500 or 800-241-3333 and reference “2020 TCPI Symposium”
    2. Reserve online – click here

    All reservations should be received by no later than Wednesday, January 22, 2020.  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 12th and 13th 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 to this conference?

    YES, especially for those seeking continuing education (CE) credits. An event app and a web-version of the app will be available for the sole use of registered attendees. Submitting questions for speakers, tracking of attendance for CE accreditation, participating in polling questions, accessing conference documents (presentations and article) and many functions will be conducted through the event app. There will be wifi and writing surface available in the conference room.

    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 17, 2020. There will be no refunds after January 17, 2020; 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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