IFA/TEI Joint Seminar

Tuesday, March 4, 2025

Program: 9:00am - 12:15pm

Lunch & Networking: 12:15pm - 1:00pm

Presented at the Andersen Silicon Valley Office

Live Seminar and Networking

This program will cover recently issued regulatory guidance, with the first panel focusing on the final digital content/software and cloud regulations and proposed cloud sourcing regulations, featuring IRS Office of Chief Counsel (International) Senior Technical Reviewer and regulation drafter, Michelle Ng, and the second panel addressing the DCL/DPL, PTEP, and sec. 987 regulations and assessing potential application of Loper Bright.

At the conclusion of this program you will understand the requirements and application of the new regulations, including a detailed overview of the rules for classifying and sourcing income from the transfer of digital content and cloud transactions and of the DCL/DPL, PTEP, and sec. 987 regulations, as well as considering potential application of Loper Bright.

REGISTRATION & PRICING:

IFA Members: Free with code
TEI Members: $50
Non-Members: $100

Cancellations must be received before February 28, 2025 - no refunds or credits after this time.

CLE/CPE CREDITS:

Recommended CLE credits: 2.75 Taxation
Recommended CPE credits: 3.25 Taxes
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour.
IFA USA National Registry Sponsor # 112000

Program Level CPE: Basic
Program Level CLE: Intermediate

Program prerequisites: None
Advanced Preparation: None

USA Branch, International Fiscal Association 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 web site: www.nasbaregistry.org

National Registry Sponsor #112000

AGENDA:

9:00 am - 9:15 am

Introduction

9:15 am - 10:30 am

US Legislative Update and Overview of Final Digital Content/Software and Cloud Regulations, and Proposed Cloud Sourcing Regulations

Stephen Bates - Principal, Ernst & Young
Michael Liu - Principal, KPMG
Zey Nasser - Managing Director, Andersen
Michelle Ng - Senior Technical Reviewer, IRS, Office of Chief Counsel (International)

10:30 am - 10:45 am

Break

10:45 am - 12:15 pm

Update on New DCL/DPL, PTEP, and sec. 987 Regulations and Loper Bright

Kodj Gbegnon - Principal, PwC
Jason Gritton - Managing Director, Andersen
Will Skinner - Partner, Fenwick
Julia Ushakova-Stein - Partner, Baker McKenzie

12:15pm - 1:00 pm

Lunch and Networking

For questions regarding registration, contact TEI Silicon Valley at teisiliconvalley@gmail.com

GENERAL INFORMATION:

Become a TEI member or Renew your membership: Enjoy seminar discounts, free social events, and a wide network of in-house tax professionals seeing the same things you are. Go to www.tei.org

TEI Membership information, visit: http://www.tei.org/membership
Questions about membership benefits, changes to the email list, contact Richard Eigenbrode at greigenbrode@gmail.com or teisiliconvalley@gmail.com

Key Legislative and Regulatory Developments and Loper Bright Considerations