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TEI CHICAGO CHAPTER - INTERNATIONAL TAX FORUM

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Offices of McDermott Will & Emery

444 West Lake Street, Chicago, IL

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We are modifying the agenda to make room for a discussion of tax reform provisions of particular interest to multinational corporations. Please note that registrations are starting to exceed the capacity of the meeting room. If you are registered and your plans have changed, please notify Irene Brajner at imbrajner@aol.com and cancel your registration in Event Brite. You will receive a refund of your fee and make room for someone else. Slides will be posted and you will receive alink to slides next week.


International Tax Forum

including breaking news on tax reform

Presented by McDermott Will & Emery and PwC

Thursday, November 16, 2017

8:00 am – 5:00 pm

McDermott Will & Emery’s Offices

444 W. Lake Street

Chicago, IL 60606

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AGENDA

8:00 – 8:25 am: Breakfast and Registration

8:25 – 8:30 am: Welcome Remarks

8:30 –10:00 am: Planning for Tax Reform, including the proposed repatriation toll charge on deferred foreign income

McDermott: David Noren, Alexander Lee | PwC: Tom Kinzler, Bryan Turner

10:00 –10:15 am: Break

10:15 –11:45 am: The proposed 20% excise tax on imports from affiliates, and the evolution of hybrid mismatch rules under BEPS Action Point 2 (“Neutralizing the Effects of Hybrid Mismatch Arrangements”), EU ATAD and local country rules - how to tax efficiently achieve “going forward” intercompany financing, IP and other relevant structures.

McDermott: Barry Quirke, Britt Haxton | PwC: Trudy Armstrong, Amelia John

11:45 – 1:00 pm: Lunch Discussion - Tax Reform Updates and Break

PwC: Larry Campbell

1:00 – 2:00 pm: Disclosures for Global Tax Strategies/Navigating Cross-Border Transactions and Privilege Concerns

McDermott: Andrew Roberson, Justin Jesse | PwC: Sergio Arellano

2:00 – 3:00 pm: Planning for 2018 and Beyond: Steps to Take Today to Position Your Organization for the Coming Year, including the impact of tax reform on §385 and interest deductions

McDermott: John Lutz, Kristen Hazel | PwC: Mikal Rabanus, Arjun Banajeree

3:00 – 3:15 pm: Break

3:15 – 4:15 pm: The Call for Substance: Discussing the Drivers and their Practical Implication to Certain Business Models, including theproposed tax on foreign high return amounts

McDermott: Sandra McGill, Mark Thomas | PwC: Ed Bodnam, Michelle Stanchina, Brad Slattery

4:15 pm: Networking Reception

Panel 1 – 8:30 – 10:00 am

Planning for Tax Reform
With the tax reform process heating up, this panel will explore the practical implications of the international tax proposals under consideration by policy makers, as well as planning measures that companies may consider taking in anticipation of tax reform. The panel will introduce key tax reform proposals of interest to multinational corporations, including the territorial concept, followed by a more in-depth discussion of how to compute the repatriation toll charge on deferred foreign income.

Panel 2 – 10:15 – 11:45 am

The proposed 20% excise tax on imports from affiliates, and the evolution of hybrid mismatch rules under BEPS Action Point 2 (“Neutralizing the Effects of Hybrid Mismatch Arrangements”), EU ATAD and local country rules - how to tax efficiently achieve “going forward” intercompany financing, IP and other relevant structures.

This panel will begin with a discussion of the proposed 20% excise tax on certain imports from affiliates. The panel will then turn to the UK hybrid mismatch rules, which are already effective as of 1/1/17. Under the EU Anti-Tax Avoidance Directive, the hybrid mismatch rules will take effect in the rest of Europe on 1/1/20. The new rules may apply directly or indirectly to existing intercompany finance (interest) and IP (royalty) arrangements and other operating structures. The panel will discuss the structures implicated by these new rules, as well as a range of tax efficient strategies to deal with them, including potential structures for operating “going forward.” The panel will also consider the implications of potential U.S. tax reform on these structures.

Lunch Discussion – 11:45 – 1:00 pm

A discussion around lobbying, the Washington DC scene, and the process of enacting tax reform legislation.

Panel 3 – 1:00 – 2:00 pm

Global Tax Strategies/Navigating Cross-Border Transactions and Privilege Concerns

With transparency and exchange of information on the rise, cross-border transactions are increasingly demanding tax departments to carefully consider the protections available to limit the disclosure of information. Privileges and protections, however, differ widely between countries. Understanding these differences is therefore critical to maintaining confidentiality in a cross-border context. This panel will evaluate the various privileges and protections available that may preclude the production of sensitive tax advice in various countries and also will provide insights into how best to use the available protections. The panel also will provide insight into the Large Business and International Division of the IRS with focus on the changes within the International program.

Panel 4 – 2:00 – 3:00 pm

Planning for 2018 and Beyond: Steps to Take Today to Position Your Organization for the Coming Year, including the impact of tax reform on §385 and interest deductions

This panel will discuss the impact of tax reform on §385 and interest deductions, before turning to recent case law addressing the process for challenging tax regulations. The panel will then address how best to position your organization for implementing new rules under TEFRA, section 385, and section 987 and for the adoption of the Multilateral Instrument by various jurisdictions where many transact business.

Panel 5 – 3:15 – 4:15 pm

The Call for Substance: Discussing the Drivers and their Practical Implication to Certain Business Models, including the proposed tax on foreign high return amounts

This panel will discuss the foundational concepts of substance, the increased focus on having “people” functions in offshore principal companies from a transfer pricing, PE and Subpart F perspective, and the practical challenges facing MNCs when trying to satisfy substance requirements. Even if you have achieved a foreign structure supported by substance, the panel will address the impact on your structure of the proposed tax on foreign high return amounts.


MCLE credit is pending in California, Illinois, New York and Texas. A Uniform Certificate of Attendance will be made available to participants requesting MCLE credit in all other states. CPE credit will also be available.

The cost for this meeting is $25 for TEI members and $55 for non-TEI members. Season ticket holders may use their season pass. No credit cards accepted at the door. This event is limited to tax professionals working in private industry. Questions – please contact Irene Brajner at imbrajner@aol.com. To register please visit: https://www.eventbrite.com/e/tei-chicago-chapter-international-tax-forum-tickets-38611094824



Date and Time

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Offices of McDermott Will & Emery

444 West Lake Street, Chicago, IL

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Refund Policy

Refunds up to 1 day before event

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