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It is important that policymakers and stakeholders understand how the taxation of business income impacts strategic business decision making, which in turn impacts where, when and how resources are invested around the world. Understanding this dynamic is fundamental to creating an effective U.S. tax policy that can attract and retain U.S. investment in the near- and long-term and keep pace in the global economy. To meet this challenge, both policymakers and stakeholders must explore:
- The importance of investment capital
- The importance of investment capital (human, financial, tangible property, intangible property) in business growth
- The role that tax policy plays in the formation, deployment, and redeployment of all types of capital
- How, in practice, tax policy shapes investment decisions, including the role of tax rates, incentives and disincentives
- Current and proposed approaches for taxing financial instruments, dividends, flow-through income and cross border transactions and their impact on capital allocation
- Possible policy changes that answer the renewed call for reform of the international provisions of the U.S. tax code
Join tax leaders from business, governments, and academia to explore the building blocks of capital allocation and their importance to some of the most pertinent tax issues facing our country and your company today.
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.
7:15AM - 8:00AM
Continental Breakfast and Registration
8:00AM - 8:20AM
Welcome Remarks and Recognition of Symposium Mission
8:20AM - 9:00AM
Opening Keynote Address
- The Honorable Bill Archer, Former Chairman, House Committee on Ways and Means; Special Policy Advisor, PwC
9:00AM - 10:00AM
Why Taxes Matter: The Economists' View
This session sets the stage for some of the topics to be covered later during the Symposium with a high-level discussion of how economists think about key tax policy issues. Topics include how the tax system affects location of investment and business operations, choice of business organizational form, leverage/debt, location of income and deductions, and the incidence of taxes, with a focus on the corporate income tax. The discussion will address how economists think about these issues conceptually, the magnitude of their potential tax effects based on empirical research, and how they relate to the current policy debate in the United States, the U.S. states, and globally.
- Sarah McGill, Senior Vice President, Tax, PepsiCo, Inc. (moderator)
- Robert Carroll, Principal, Quantitative Economics and Statistics (QUEST), Ernst & Young LLP
- Ruud A. De Mooij, Deputy Division Chief, Tax Policy Division, International Monetary Fund (IMF)
- Donald Marron, Institute Fellow and Director of Economic Policy Initiatives, Urban Institute
10:00AM - 10:15AM
10:15AM - 11:15AM
Why Taxes Matter: The CFO's view
Understanding how corporate income taxes actually factor into strategic and investment decisions is fundamental to developing a U.S. tax policy that is competitive and effective. This panel will explore the role that taxes play in shaping strategic decisions. Discussion will focus on issues such as the impact of tax incentives on decisions to invest in innovation and the impact that taxes can have on the most common corporate performance metrics.
- T. Timothy Tuerff, Partner, International Tax Services Group, Washington National Tax, Deloitte Tax LLP (moderator)
- Charles Alsdorf, Director, Capital Efficiency Services, Deloitte Financial Advisory Services LLP
- Martina Hund-Mejean, Chief Financial Officer, MasterCard
- Steven M. Sterin, Senior Vice President and Chief Financial Officer, Celanese Corporation
- J. Kevin Willis, Senior Vice President and Chief Financial Officer, Ashland, Inc.
11:15AM - 12:30PM
Other Aspects of a Competitive Tax System: Balancing Base Broadening and Rate Reduction
This panel will address the impact of broadening the tax base by looking at specific proposals and considering the potential rate and other trade-offs necessary to achieve a supportable tax reform proposal. The panel will also explore base-broadening options employed by other countries to achieve lower corporate rates.
- Pamela Olson, U.S. Deputy Tax Leader & WNTS Leader, PwC (moderator)
- Diane Dossin, Chief Tax Officer, Ford Motor Company
- Michael D. Fryt, Corporate Vice President Tax, FedEx Corporation
- Michael Reilly, Vice President, Taxation, Johnson & Johnson
- Jaime Spellings, Vice President, General Tax Counsel, Exxon Mobil Corporation
12:30PM - 1:45PM
Lunch and Pillar of Excellence Award Presentation
2014 Pillar of Award Presentation:
Recipient: Janice Mays, Democratic Chief of Staff and Chief Counsel, House Committee on Ways and Means
1:45PM - 2:00PM
2:00PM - 3:00PM
Other Aspects of a Competitive Tax System: The Role of Taxation in the Deployment of Financial Capital
This panel will focus on how tax rules in the United States and abroad affect how companies choose to deploy capital through equity, debt, or hybrid instruments.
- Micah S. Green, Partner, Patton Boggs LLP (moderator)
- Benjamin Berinstein, Managing Director, JP Morgan Chase
- Erika W. Nijenhuis, Partner, Cleary Gottlieb Steen & Hamilton LLP
- Laurence Salva, Managing Director – Corporate Tax Department, Citigroup
3:00PM - 4:00PM
Who Pays Tax: Achieving Greater Parity between Corporate and Flow Through Entities
This panel will explore the implications of shifting from two levels of tax on corporate income to one, how other jurisdictions have accomplished it, and what issues and obstacles the United State might face.
- Hank Gutman, Principal, KPMG LLP (moderator)
- William L. Curry, Chief Tax Officer & Assistant Secretary, The Dow Chemical Company
- Kenneth W. Gideon, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
- Simon Palmer, Partner, International Tax, KPMG LLP
- The Honorable Bill Thomas, Former Chairman, House Committee on Ways and Means
- Alan D. Viard, Resident Scholar, American Enterprise Institute (AEI)
4:00PM - 4:30PM
4:30PM - 5:30PM
Revenue Estimating: Process and Policy Implications
This panel will explore the role revenue estimating plays (or should play) in the legislative process, and why it matters from policy, political, and procedural standpoints. It will also attempt to provide a better understanding of how the Joint Committee on Taxation staff prepares revenue estimates and the benefits (and drawbacks) of making the process more transparent.
- Jonathan Traub, Managing Principal, Tax Policy Group, Washington National Tax, Deloitte Tax LLP (moderator)
- Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation
- John Diamond, Edward A. and Hermena Hancock Kelly Fellow in Tax Policy, Rice University
- Rohit Kumar, Principal and Co-Leader, Tax Policy Services, PwC
- Janice Mays, Democratic Staff Director and Chief Counsel, House Committee on Ways and Means
5:30PM - 7:30PM
7:30AM - 8:00AM
8:00AM - 8:30AM
Jason Furman, Chairman, The White House Council of Economic Advisors
8:30AM - 9:30AM
Current Issues in State and Local Tax: Capital Allocation Effects and Lessons for International Tax Reform
This panel will focus on current hot topics in state and local tax and how they can inform the debate on international tax reform, focusing in particular on attracting capital while protecting a revenue base. Areas to be explored include formulary apportionment and its impact on capital allocation, what we can learn from the Business Activities Tax Simplification Act / Marketplace Fairness Act, and cloud computing tax issues.
- David G. Noren, Partner, McDermott Will & Emery LLP (moderator)
- Robert Cline, National Director, State and Local Tax Policy Economics, Ernst & Young LLP
- Stephen P. Kranz, Partner, Partner, McDermott Will & Emery LLP
- Douglas L. Lindholm, President & Executive Director, Council on State Taxation (COST)
- Richard Pomp, Alva P. Loiselle Professor of Law, UConn School of Law
9:30AM - 10:30AM
Cross Border Taxation: Exploring Option
Many options for reforming international tax have been suggested over the years, and the debate has intensified over concerns about global competition and economic growth. This panel will explore several of these options, with an emphasis on (1) their potential impact on foreign direct investment in the United States and investments of U.S. multinationals abroad, and (2) similar reforms enacted recently in other jurisdictions and the lessons we can learn from them.
- Gretchen Sierra, Principal, International Tax Services Group, Washington National Tax, Deloitte Tax LLP (moderator)
- Rosanne Altshuler, Chair, Department of Economics, Rutgers University
- Ray Beeman, Tax Counsel and Special Advisor for Tax Reform, House Committee on Ways and Means
- Ronald Dickel, Vice President, Global Tax and Trade, Intel Corporation
- David P. Lewis, Vice President, Global Taxes; Chief Tax Executive & Assistant Treasurer, Eli Lilly and Company
- Mike Williams, Director, Business International Tax, HM Treasury
10:30AM - 11:00AM
11:00AM - 12:00PM
Cross Border Taxation: Base Erosion and Profit Shifting (BEPS) Update
The growth of the global economy and the rise of new business models that highlight the importance of intangibles and the digital economy, together with the perceived increased use of hybrid instruments and hybrid entities, have fueled allegations that existing tax regimes haven’t kept pace and are creating a shift of income away from jurisdictions where the activities that created it reside. This panel will explore the potential U.S. response to the first set of Action Items from the OECD BEPS project, the role of tax treaties, and the potential administrative burdens implicit in the changes in a point, counterpoint, between an OECD official and a U.S. Treasury official.
- Philip D. Morrison, Principal, International Tax Services Group, Washington National Tax, Deloitte Tax LLP (moderator)
- Will Morris, Chair, BIAC Tax Committee; Senior International Tax Counsel and Director, Tax Policy, General Electric
- Raffaele Russo, Head of the BEPS Project, OECD Centre for Tax Policy and Administration
- Robert Stack, Deputy Assistant Secretary (International Tax Affairs), U.S. Department of the Treasury
- Mike Williams, Director, Business International Tax, HM Treasury
12:00PM - 1:00PM
Why Taxes Matter: Bringing It All Together
This panel will bring together the most prominent existing uncertainties and challenges in tax policy and then explore how tax professional can advise their clients in this environment. Discussion topics will include assessing the risks and managing within the existing ambiguity, the potential consequences of inaction, and the implications of existing proposals for U.S. taxpayers. The panel will close with a discussion of an action plan for moving forward.
- David P. Lewis, Vice President, Global Taxes; Chief Tax Executive & Assistant Treasurer, Eli Lilly and Company (moderator)
- Manal Corwin, Principal and National Leader, International Tax, KPMG LLP
- Kevin G. McWilliams, Vice President Tax, International Paper
- Paul Oosterhuis, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
1:00PM - 1:15PM