International Tax Issues 2022 - New York | PLI Practising Law Institute | 1 February 2022 | Practising Law Institute, 1177 6th Ave, New York, NY 10036, USA

As the world’s economies emerge from the economic devastation of COVID-19 and countries seek to increase their tax base to pay for the extraordinary expenditures related to the pandemic, or further social programs, navigating the U.S. international tax rules remains imperative for those doing business, and making investments, cross-borders. These international tax rules affect not only large U.S. and non-U.S. based multinationals, but also increasingly affect mid-sized and smaller organizations and investors, financing transactions, mergers and acquisitions, and other commercial activity.

At this year’s program we will assemble some of the world’s leading experts and senior government officials to discuss the complex rules of U.S. international taxation in light of the 2017 Tax Act (formerly the Tax Cuts and Jobs Act – “TCJA”), as well as the recent legislative efforts meant to turn the available levers in TCJA to significantly increase social spending. We will focus upon both operational and transactional implications of the changed rules and environment and describe the application of the rules to both U.S. and non-U.S. based organizations and investors.

Topics Include:

• Transfer pricing developments and transfer pricing’s role in global intangible low-taxed income (“GILTI”) and foreign-derived intangible income (“FDII”) provisions
• The impact of OECD developments, treaty developments and rules intended to combat base erosion, as well as the hybrid provisions included in the TCJA
• Cross-border merger and acquisition issues, techniques, and developments, in light of legislative change.
• Changes to the anti-deferral rules, foreign tax credits and domestic incentives
• Dealing with international joint ventures, revisiting fund structures and the new paradigm shift for the partnership form

Who Should Attend?

Law firm and accounting firm professionals who advise clients on structuring cross border transactions, and on international tax planning and controversy matters; in-house tax professionals involved in cross-border and internal planning, in FIN 48 determinations and in IRS audits and appeals of international issues; and government attorneys who want to stay on top of what’s happening in the international tax arena will benefit from attending this program.

2022 Speakers

Michael A. DiFronzo
Principal, PwC

Stephen R.A. Bates
Principal, EY

Devon M. Bodoh
Partner, Weil, Gotshal & Manges LLP

Diana S. Doyle
Chairs, Latham & Watkins LLP

Angela E. Holland
Senior Counsel, Office of the Associate Chief Counsel (International), Branch 6, Internal Revenue Service

Danielle E. Rolfes
Co- Leads, KPMG LLP

Gregory R. Walker
Principal, Ernst & Young LLP's

Thomas M. Zollo
Principal, KPMG LLP

PROGRAM ATTORNEY:

Stacey L. Greenblatt
Senior Program, PLI’s Tax Law