Capital Matters: How Taxes Influence the Global Creation, Deployment, and Mobility of Capital

Continental Breakfast and Registration

Welcome Remarks and Recognition of Symposium Mission

CFOs View: Exploring the Impact and Influence of Tax

All businesses know that tax policy decisions often also shape business decisions. In the case of capital investment, deployment, and location, the applicable tax rules inevitably shape the decisions companies make. This panel of CFOs will discuss how these tax rules influence business decisions and whether that is a good thing or a bad thing. Further, this panel will also discuss methodologies for measuring results from the tax function.

- Jeffrey LeSage, Vice Chairman, Tax Practice, KPMG LLP (moderator)
- Timothy Berger, Senior Vice President, Group Executive-Corporate Tax, MasterCard
- Robert Corti, former Chief Financial Officer, Avon Products
- Chris Miller, Vice President of Tax, T-Mobile USA

Economists View: A Closer Look at the Economics of Capital Taxation

What does the science of economics tell us about the effect of taxes on the formation and deployment of capital? This panel of economists will explore whether tax policy can play an important role and whether economic theory can help answer that question. For example, in the context of tax reform, should an objective of tax policy be to eliminate insofar as possible the effect of taxation across various types of capital, or should instead some types of capital be favored over others?

- Martin Sullivan, Chief Economist, Tax Analysts (moderator)
- Robert Carroll, National Director, Quantitative Economics and Statistics (QUEST), EY
- Adam Looney, Deputy Assistant Secretary for Tax Analysis, U.S. Department of the Treasury
- Eric Toder, Institute Fellow and Codirector, Tax Policy Center, Urban Institute
- Alan Viard, Resident Scholar, American Enterprise Institute (AEI)

Break

Capitalization: Finding a Better Way

Does the math of tax reform require a change to the current capitalization and cost recovery regime? If change is inevitable, is there a better approach than the current systems of capitalization and cost recovery and other rules governing capital investment? What can we learn from recent proposals and from other jurisdictions?

- Mary Duffy, Managing Director, Andersen Tax (moderator)
- Ray Beeman, Principal, Washington Council EY
- Diane Dossin, Chief Tax Officer, Ford Motor Company
- Jude Lemke, Vice President Tax, Corning Incorporated
- Eric J. Lucas, Principal, KPMG LLP

Luncheon Keynote Address & Presentation of the TCPI Pillar of Excellence Award

2016 Recipient: Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation

Capital Investment: A Tale of Two Financing Options

Taxpayers generally have two options in financing capital acquisitions: debt or equity. Using a case study, the panel will examine how the differing tax treatments of these two options affect real-world decisions. The role that these tax rules play in shaping of the decisions surrounding debt and equity financing of capital investments will be explored by drawing upon the insights of these experts.

- Robin Greenhouse, Partner, McDermott Will & Emery (moderator)
- Madeleine Barber, Chief Tax Officer, Tyco International
- Kate Collier, Vice President and Treasurer, Sempra Energy
- Joseph Pari, National Principal-in-Charge, Washington National Tax, KPMG LLP

Break

Taxing Genius: Examining Intellectual Capital Tax Policy

Taxation of intellectual capital has long been one of the most vexing problems for policy makers and tax administrators. How, when, and where to tax intellectual capital is a topic of discussion in the United States and around the world. The panel will engage in a practical back-and-forth discussion of how tax policy affects the way businesses develop and deploy intellectual capital.

- Christopher Wolter, Vice President of Taxes, The Boeing Company (moderator)
- Ronald D. Dickel, Vice President, Finance; Director, Global Tax and Trade, Intel Corporation
- Nathaniel Carden, Partner, International Tax and Tax Controversy, Skadden, Arps, Slate, Meagher & Flom LLP
- Matthew Slaughter, Paul Danos Dean, Tuck School of Business at Dartmouth

Corporate Taxation: Understanding the Potential of Integration

For decades, the United States has considered how to improve its system of taxing corporate businesses. The current system of double taxation of “C corporations” has been blamed for an erosion of the corporate tax base as businesses increasingly choose partnerships, S corporations, MLPs, and REITs. The Senate Finance Tax Reform working groups have once again brought this issue to the fore. The panel will explore integration options that are currently being considered and the practical implications thereof, including how they might affect the accumulation of capital, base erosion, business decisions, and financial markets.

- Pam Olson, US Deputy Tax Leader & Washington National Tax Services Leader, PwC (moderator)
- Christopher Hanna, Senior Policy Advisor for Tax Reform (Republican), Senate Finance Committee
- David A. Heywood, Vice President, Taxes & General Tax Counsel, Lockheed Martin Corporation
- Timothy M. McDonald, Vice President - Global Taxes, Procter & Gamble

The Policymakers' View: How Presidential Campaigns Steer Tax Policy

Advisors to successful presidential candidates describe how they generated the tax policy initiatives that their candidates advocated during the primary and the general elections. The panelists will then compare how those campaign proposals evolved into legislation that the President championed and, in many cases, eventually signed into law. By highlighting the forces impacting a presidential candidate's policy positions as well as economic proposals once elected, these policy experts can help tax directors and advisors project which 2016 proposals businesses should prepare to see debated in 2017 and incorporated into the tax code.

- Russ Sullivan, Partner, McGuireWoods (moderator)
- Bruce Reed, Co-chair - Initiative on The Future of Work, The Aspen Institute (Clinton campaign)
- Bruce Thompson, Senior Policy Advisor, DLA Piper (Reagan campaign)

Networking Reception

Continental Breakfast

Keynote Address

- Chairman Kevin Brady (R-TX), House Committee on Ways and Means

Beyond Borders: The Global Mobility of Capital and Taxes

Capital knows no borders. In recent years we have seen a growing wave of cross-border transactions. The trend of inversions and of inbound acquisitions is a reminder of this reality. The panel will discuss the role tax rules play in the cross-border mobility of capital and will explore potential solutions and alternative regimes to make the movement of capital more efficient.

- David P. Lewis, Vice President - Global Taxes; Chief Tax Executive & Assistant Treasurer, Eli Lilly and Company (moderator)
- Devon Bodoh, Principal-in-Charge of Washington National Tax International M&A Group, KPMG LLP
- Douglas Cronin, Vice President, Corporate Tax, Boston Scientific Corporation
- Danielle Rolfes, International Tax Counsel (Office of Tax Policy), U.S. Department of the Treasury
- Joel Walters, Partner – Leader, US Inbound Tax and Global Tax Communications, PwC

Break

The Implementer's View: BEPS in Action

Discover how key governmental BEPS decision-makers believe the final BEPS action plan will be adopted and implemented by participant countries.

- Manal Corwin, Principal and National Leader, International Tax, KPMG LLP (moderator)
- Brian Ernewein, General Director (Legislation), Tax Policy Branch, Department of Finance Canada
- Douglas O'Donnell, Commissioner, Large Business and International (LB&I), Internal Revenue Service
- Robert Stack, Deputy Assistant Secretary (International Tax Affairs), U.S. Department of the Treasury
- Mike Williams, Director of the Business and International Tax, HM Treasury

The Tax Director's View: Meeting the BEPS Challenge

The OECD has now released “Final Reports” on the 15 BEPS Action Items. Resolution of several critical issues have been put off, however, until 2016 and later. Further, while some of the recommendations in these reports may be self-executing, many require countries to pass legislation or amend treaties. This panel of Tax Directors will discuss how they will deal with ongoing OECD work, country implementation, and the critical question of whether they need to adjust their company’s transfer pricing implementation and procedures in light of these new rules. The panel will also discuss how their companies will deal with certain country legislation that goes further than the Reports’ recommendation, as well as tax authorities that use the BEPS as a general concept to propose disallowances.

- T. Timothy Tuerff, Managing Partner, Washington National Tax, Deloitte Tax LLP (moderator)
- Jacqueline Crouse, Vice President, Tax, Amgen Inc.
- Joe Hajek, Senior Vice President, Tax & Government Affairs, Tupperware Brands Corporation
- Ross Kearney, Corporate Vice President, Tax, United Technologies Corporation
- Saul Rosen, Senior Tax Counsel and Managing Director, Citigroup
- William J. Sample, Corporate Vice President, Worldwide Tax, Microsoft Corporation

Closing Remarks