32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela...

16
32nd Annual Deputy Commissioner (International), LB&I Associate Chief Counsel (International) December 19 & 20, 2019 Institute on Current Issues in International Taxation

Transcript of 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela...

Page 1: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

32nd Annual

Deputy Commissioner (International), LB&I Associate Chief Counsel (International)

December 19 & 20, 2019

Institute on Current Issues in

International Taxation

Page 2: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

T

The Institute 2

32nd ANNUAL INSTITUTE ON

CURRENT ISSUES IN

INTERNATIONAL TAXATION

The Institute’s first panel will

be a discussion on global tax

trends and digitalization of the

economy. The Institute will also

address key practical issues faced

by tax practitioners, corporate

tax executives, and the Internal

Revenue Service, with private

sector and government panelists

discussing, among other things,

FDII, GILTI, foreign tax credits,

repatriation, cross-border

individual matters, other current

developments, BEAT, cross-border

financing, and ethics.

The Institute will conclude with a panel on “Views from the Government”

that will include both Treasury and IRS officials and will involve a

roundtable discussion of important topics from senior international tax

government officials.

The program is designed to encourage an exchange of views between

government and private sector panelists and to provide a forum for

attendees to participate in the panel discussions by posing questions to

the panelists.

Current Issues in International Taxation is designed for

• Corporate tax executives responsible for international tax matters

• Law firm partners and associates working in the international tax area

• Accounting firm partners and managers working in the international tax area

• Members of the academic community interested in the latest technical developments in international taxation

• Internal Revenue Service personnel working in international tax

the I n s t i t u t e

Page 3: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

http://www.tggroup.com/GWUIRSInstitute/ 3

the Institute at a GlanceThursday, December 19, 2019

7:15 am - 8:00 am Breakfast

8:00 am - 8:15 am Welcome and Introductions

8:15 am -10:00 am Digitization of the Economy

10:00 am - 10:15 am Break

10:15 am - 11:15 am FDII

11:15 am - 12:15 pm GILTI

12:15 pm – 1:45 pm Luncheon with Address

2:00 pm - 3:00 pm Foreign Tax Credits

3:00 pm – 4:00 pm Repatriation (PTI/245A)

4:00 pm - 4:15 pm Break

4:15 pm - 5:00 pm Cross-Border Individual Matters

5:00 pm – 6:00 pm Other Current Developments

6:00 pm - 7:00 pm Reception

Friday, December 20, 2019

7:30 am - 8:30 am Breakfast

8:30 am - 9:30 am BEAT

9:30 am - 10:30 am Cross-Border Financing

10:30 am - 10:45 am Break

10:45 am - 11:45 am Ethics

12:00 pm - 1:30 pm Luncheon with Address

1:30 pm - 1:45 pm Break

1:45 pm - 2:45 pm Views From the Government

Page 4: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

the A g e n d a

4 The Agenda

Thursday, December 19, 2019 Wifi sponsored by

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the Wifi and their participation is not intended as an endorsement of the sponsor

7:15 am – 8:00 am Breakfast

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the breakfast and their participation in the breakfast is not intended as an endorsement of the sponsor.

8:00 am – 8:15 am Welcome and Introductions Hal Hicks Partner, Skadden, Arps, Slate, Meagher & Flom LLC, Washington, DC

Robert J. Peroni The Fondren Foundation Centennial Chair for Faculty Excellence and Professor of Law, The University of Texas School of Law, Austin, TX

Peter H. Blessing Associate Chief Counsel (International), Internal Revenue Service, Washington, DC

Theodore D. Setzer Assistant Deputy Commissioner (International), Internal Revenue Service, Washington, DC

8:15 am – 10:00 am Digitalization of the Economy: Reshaping taxing rights and profit allocations – can double taxation be avoided?

Co-Chairs: Arlene S. Fitzpatrick Principal, National Tax - International Tax Services, Ernst & Young LLP,

Washington, DC

Theodore D. Setzer Assistant Deputy Commissioner (International), Internal Revenue Service, Washington, DC

Panelists: Samuel M. Maruca Partner, Covington & Burling LLP, Washington, DC

Timothy M. McDonald Vice President, Global Taxes, Proctor & Gamble Company, Cincinnati, OH

Pamela Olson U.S. Deputy Tax Leader & WNTS Leader, PricewaterhouseCoopers LLP, Washington, DC

Grace Perez-Navarro Deputy Director, CTPA, Organization for Economic Co-operation and Development (OECD), Paris, France

Robert B. Stack Managing Director, Washington National and International Tax, Deloitte Tax LLP, Washington, DC

Jennifer L. Best Executive Officer, (LBI), Internal Revenue Service, Washington, DC

the A g e n d a

Page 5: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

5http://www.tggroup.com/GWUIRSInstitute/

Quyen Huynh ITC, International Tax Counsel for Treaty Affairs, U.S. Department of Treasury, Washington, DC

Work is well under way at the OECD to address the tax challenges raised by the digitalization of the economy. Among the paradigm-shifting issues under consideration are new nexus rules and the design features for a minimum tax. This panel will explore the progress made to date, the changes contemplated with respect to the international tax framework, including current transfer pricing principles, and the challenges that await taxpayers and tax administrations alike in the interest of ensuring tax certainty and avoiding double taxation.

10:00 am – 10:15 am Break

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the break and their participation in the break is not intended as an endorsement of the sponsor.

10:15 am – 11:15 am FDII Chair: Michael A. DiFronzo Partner, Washington National Tax Services,

PricewaterhouseCoopers LLP, Washington, DC

Panelists: John D. Bates Partner, Deloitte Tax LLP, Washington, DC

Karen B. Brown Theodore Rinehart Professor of Business Law, The George Washington University, Washington, DC

Jeffrey M. Tebbs International Tax Counsel – Tax Department, Lockheed Martin Corporation, Washington, DC

Kenneth A. Jeruchim ACCI, Attorney-Advisor, Internal Revenue Service, Washington, DC

Brigid Kelly ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC

The panel will explore a range of issues raised by the new FDII regime and accompanying regulations. The panel will focus on common and unique issues related to the sale of goods, license of IP and the provision of services. Specific topics explored will include:

• Sale of Movable Property.

• Effects of Contracts and Use on IP Income.

• Provision of Mobile Services.

• Determination of FDII and Allocation of Deductions.

• Industry Specific Issues.

• Documentation for FDII Benefits.

Page 6: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

the A g e n d a

6 The Agenda

11:15 am – 12:15 pm GILTI Chair: Lori A. Hellkamp Partner, Jones Day, Washington, DC

Panelists: Rachel D. Kleinberg Partner, Davis Polk & Wardwell LLP, Menlo Park, CA

David G. Noren Partner, McDermott Will & Emery LLP, Washington, DC

Agnieszka E. Samoc Vice President, Tax Counsel, Danaher Corporation, Washington, DC

John J. Merrick ACCI, Senior Level Counsel, Internal Revenue Service, Washington, DC

Wade Sutton ITC, Senior Counsel to the International Tax Counsel, U.S. Department of Treasury, Washington, DC

This panel will explore a range of issues raised by the GILTI regime, including the final GILTI regulations, the GILTI high-tax exception, and GILTI considerations in structuring and M&A.

12:15 pm – 1:45 pm Luncheon with Address by Michael J. Desmond, Chief Counsel of the IRS and Assistant General Counsel in the Department of the Treasury

2:00 pm – 3:00 pm Foreign Tax Credits Chair: Eric B. Sensenbrenner Partner, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, DC

Panelists: Layla J. Asali Member, Miller & Chevalier Chartered, Washington, DC

Michael J. Caballero Partner, Covington & Burling LLP, Washington, DC

Glen Pfeiffer International Tax Counsel, GE Treasury, Norwalk, CT

Barbara Felker ACCI, Branch Chief, Internal Revenue Service, Washington, DC

Jason Yen ITC, Attorney-Adviser, U.S. Department of Treasury, Washington, DC

The foreign tax credit system has taken on greater importance in the age of tax reform, particularly as a result of the GILTI regime. This panel will discuss recently-issued guidance addressing the application of the foreign tax credit in light of the GILTI provisions, the impact of interest and other expense allocation, and other issues regarding the foreign tax credit system that are raised by tax reform.

3:00 pm – 4:00 pm Repatriation (PTI/245A) Chair: Nicholas J. DeNovio Partner, Latham & Watkins LLP, Washington, DC

Panelists: Amie Colwell Breslow Of Counsel, Jones Day, Washington, DC

Jose E. Murillo Partner, Ernst & Young LLP, Washington, DC

Moshe Spinowitz Partner, Skadden, Arps, Slate, Meagher & Flom LLP, Boston, MA

the A g e n d a

Page 7: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

7http://www.tggroup.com/GWUIRSInstitute/

Melinda E. Harvey ACCI, Branch Chief, Internal Revenue Service, Washington, DC

Brenda Zent ITC, Special Advisor to the International Tax Counsel, U.S. Department of Treasury, Washington, DC

•How has the repatriation issue evolved from the pre-TCJA era?

•Qualification under section 245A, including restrictions under recent regulations.

•Calculation and treatment of Previously Taxed Earnings & Profits (PTEP) accounts, including special issues such as Partnerships.

•Basis Adjustments under section 961.

•The challenges for bringing home PTEP, including the special rules that apply to PTEP created under section 965.

4:00 pm – 4:15 pm Break

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the break and their participation in the break is not intended as an endorsement of the sponsor.

4:15 pm – 5:00 pm Cross-Border Individual Matters Chair: Amanda P. Varma Partner, Steptoe & Johnson LLP, Washington, DC

Panelists: Kirsten Burmester Member, Caplin & Drysdale, Chartered, Washington, DC

Summer Ayers LePree Partner, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL

Natalie Punchak ACCI, General Attorney, Internal Revenue Service, Washington, DC

James Wang ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC

This panel will discuss recent developments impacting the taxation of outbound and inbound cross-border investments by individuals. Specific topics covered may include:

•GILTI and other outbound planning issues for individual U.S. shareholders, including how the proposed GILTI high-tax exception may impact an individual’s decision to make a section 962 election.

•Implications of section 958 on U.S. individual ownership of foreign corporations through domestic partnerships, including the effect on PFICs.

•Lingering section 965 issues for individuals.

•Practical issues raised by the proposed section 1446(f) regulations.

•Tax treaty application to individuals.

•FIRPTA and other international tax issues for foreign investors in qualified opportunity zones.

Page 8: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

the A g e n d a

8

5:00 pm – 6:00 pm Other Current Developments Chair: Mary C. Bennett Senior Counsel, Baker & McKenzie LLP, Washington, DC

Panelists: Joan C. Arnold Partner, Pepper Hamilton LLP, Philadelphia, PA

Brian Davis Partner, BakerHostetler, Washington, DC

Kimberly Tan Majure Partner, KPMG LLP, Washington, DC

Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC

Raymond J. Stahl ACCI, Special Counsel, Internal Revenue Service, Washington, DC

This panel will address current topics not covered in other sessions. While selection of the final content will depend on issues that are hot at the time of the conference, potential topics will include:

•Current treaty issues.

•Inbound developments.

•PFIC regulations.

•Significant court decisions.

6:00 pm – 7:00 pm Reception

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the reception and their participation in the reception is not intended as an endorsement of the sponsors.

the A g e n d a

The Agenda

Page 9: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

http://www.tggroup.com/GWUIRSInstitute/ 9

Friday, December 20, 2019 Wifi sponsored by

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the Wifi and their participation is not intended as an endorsement of the sponsor

7:30 am – 8:30 am Breakfast

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the breakfast and their participation in the breakfast is not intended as an endorsement of the sponsor.

8:30 am – 9:30 am BEAT Chair: Danielle Rolfes Partner, KPMG LLP, Washington, DC

Panelists: Rafic H. Barrage Partner, Baker & McKenzie LLP, Washington, DC

Rocco V. Femia Member, Miller & Chevalier Chartered, Washington, DC

Saren Goldner Partner, Eversheds Sutherland LLP, New York, NY

Azeka J. Abramoff ACCI, General Attorney, Internal Revenue Service, Washington, DC

Kevin Nichols ITC, Senior Counsel to the International Tax Counsel, U.S. Department of Treasury, Washington, DC

This panel will discuss the Base Erosion and Anti-avoidance Tax (BEAT) and its impact on business operations, including:

•Interaction with transfer pricing and the ownership of tangible property.

•Scope of exception for services.

•Impact on common business models and restructurings.

•The scope of the anti-abuse rules.

9:30 am – 10:30 am Cross-Border Financing Chair: Gary B. Wilcox Partner, Mayer Brown, Washington, DC

Panelists: Michael T. Mollerus Partner, Davis Polk & Wardwell LLP, New York, NY

Caroline H. Ngo Partner, McDermott Will & Emery, Washington, DC

Elena Romanova Partner, Lathan & Watkins LLP, New York, NY

Page 10: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

the A g e n d a

The Agenda

the A g e n d a

10

Shane M. McCarrick ACCI, Senior Counsel, Internal Revenue Service, Washington, DC

Brett York ITC, Associate International Tax Counsel, U.S. Department of Treasury, Washington, DC

The panel will explore the key threshold questions of where should U.S.- and foreign-based multinationals locate their external and inter-nal debt within their organizations, and how should their debt be structured, in light of the many complicated, and often intersecting, rules that either limit the tax benefits of using debt or increase expo-sure under various regimes by virtue of using debt. Topics to be dis-cussed include:

•Impact of interest expense apportionment regulations on GILTI, and potential worldwide allocation rule.

•Coordination of section 163(j) limitations with hybrid rules and BEAT exposure.

•Under what circumstances do section 385 regulations still matter?

•How best to structure cash pooling arrangements.

10:30 am – 10:45 am Break

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the break and their participation in the break is not intended as an endorsement of the sponsor.

10:45 am – 11:45 am Ethics Chair: Linda Galler Max Schmertz Distinguished Professor of Law, Maurice A. Deane

School of Law at Hofstra University, Hempstead, NY

Panelists: Diane Ring Professor of Law and The Dr. Thomas F. Carney Distinguished Scholar,

Boston College Law School, Boston, MA

Christopher Rizek Member and General Counsel, Caplin & Drysdale, Chartered, Washington, DC

Paul Manning ACCI, Special Counsel, Internal Revenue Service, Washington, DC

Through interactive discussion of case studies, this panel explores the range of ethical issues confronting government and private sector tax professionals in international tax practice, and considers those issues under the applicable ethical rules (including ABA Model Rules, AICPA Code and Statements, Circular 230, and Standards of Ethical Conduct for Employees of the Executive Branch). Topics may include ethical issues arising in:

•Taking tax positions and giving tax advice in an age of uncertainty.

•International tax controversies.

Page 11: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

11http://www.tggroup.com/GWUIRSInstitute/

•International tax planning and transactions, including duties regarding foreign law and to foreign tax authorities.

•IRS and Treasury international tax rulemaking and policymaking.

12:00 pm – 1:30 pm Luncheon with Address by David J. Kautter, Assistant Secretary for Tax Policy, U.S. Department of the Treasury

1:30 pm – 1:45 pm Break

*The Internal Revenue and the U.S. Department of Treasury are not sponsoring the break and their participation in the break is not intended as an endorsement of the sponsor.

1:45 pm – 2:45 pm Views From the Government Moderator: Peter H. Blessing Associate Chief Counsel (International), Internal Revenue Service,

Washington, DC

Panelists: Robin Greenhouse Acting Division Counsel (LBI Counsel), Internal Revenue Service,

Washington, DC

L.G. “Chip” Harter ITC, Deputy Assistant Secretary for International Tax Policy, U.S. Department of Treasury, Washington, DC

John E. Hinding Director, Cross Border Activities, LBI, Internal Revenue Service, Washington, DC

Theodore D. Setzer Assistant Deputy Commissioner (International), Internal Revenue Service, Washington, DC

Page 12: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

Advisory Board

y

12

J. Clark Armitage Member Caplin & Drysdale, Chartered Washington, DC

Joan C. Arnold Partner Pepper Hamilton LLP Philadelphia, PA

Layla J. Asali Member Miller & Chevalier Chartered Washington, DC

Rafic H. Barrage Partner Baker & McKenzie LLP Washington, DC

Mary C. Bennett Partner Baker & McKenzie LLP Washington, DC

Karen B. Brown Theodore Rinehart Professor of Business Law The George Washington University Washington, DC

Kirsten Burmester Member Caplin & Drysdale, Chartered Washington, DC

Michael J. Caballero Partner Covington & Burling LLP Washington, DC

Manal S. Corwin Principal and National Leader International Taxation KPMG LLP Washington, DC

Robert E. Culbertson Partner Covington & Burling LLP Washington, DC

Anne O’Connell Devereaux Deputy Associate Chief Counsel (International Field Service & Litigation) IRS Office of Chief Counsel, Internal Revenue Service Washington, DC

Nicholas DeNovio Partner Latham & Watkins, LLP Washington, DC

Eli J. Dicker Executive Director Tax Executives Institute, Inc. Washington, DC

Michael A. DiFronzo Partner, Washington National Tax Services PricewaterhouseCoopers LLP Washington, DC

Kathleen S. Fanning Vice President, Worldwide Taxes Xerox Corporation Norwalk, CT

Rocco Femia Member Miller & Chevalier Chartered Washington, DC

Tadd Fowler Vice President – Global Tax The Procter & Gamble Company Cincinnati, OH

Saren Goldner Partner Eversheds Sutherland LLP New York, NY

Mark D. Harris Senior Tax Counsel The Coca-Cola Company Atlanta, GA

L.G. “Chip” Harter Deputy Assistant Secretary for International Tax Policy U.S. Department of Treasury Washington, DC

Lori A. HellKamp Partner Jones Day Washington, DC

Rachel D. Kleinberg Partner Davis Polk & Wardwell LLP Menlo Park, CA

Katie Lodato Vice President – Global Tax Eli Lilly and Company Indianapolis, IN

Kimberly Tan Majure Partner KPMG LLP Washington, DC

Daniel M. McCall Deputy Associate Chief Counsel International (Technical) Internal Revenue Service Washington, DC

Jose Murillo Partner Ernst & Young LLP Washington, DC

Michael F. Mundaca Co-Director, National Tax Ernst & Young LLP Washington, DC

David G. Noren Partner McDermott Will & Emery LLP Washington, DC

Douglas W. O’Donnell Commissioner, Large Business and International Division Internal Revenue Service Washington, DC

Pamela F. Olson U.S. Deputy Tax Leader & WNTS Leader PricewaterhouseCoopers LLP Washington, DC

Douglas Lloyd Poms International Tax Counsel Office of Tax Policy, U.S. Department of Treasury Washington, DC

William J. Sample Vice-President – Tax Microsoft Corp Redmond, WA

Paul M. Schmidt Chairman BakerHostetler Washington, DC

Benjamin R. Shreck Tax Counsel Tax Executives Institute, Inc. Washington, DC

Gretchen T. Sierra Principal, International Tax Deloitte Tax LLP Washington, DC

Moshe Spinowitz Partner Skadden, Arps, Slate, Meagher & Flom LLP Boston, MA

Robert B. Stack Managing Director, Washington National and International Tax Deloitte Tax LLP, Washington, DC

Carol P. Tello Partner Eversheds Sutherland Washington, DC

Philip R. West Partner Steptoe & Johnson LLP Washington, DC

Gary B. Wilcox Partner Mayer Brown Washington, DC

Lowell D. Yoder Partner McDermott Will & Emery LLP Chicago, IL

Brenda L. Zent Special Advisor to the International Tax Counsel U.S. Department of Treasury Washington, DC

The Institute gratefully recognizes the support and assistance of members of the Advisory Board in the selection of topics and speakers for this program.Co-Chair Hal Hicks Partner Skadden, Arps, Slate, Meagher & Flom LLC Washington, DC

Co-Chair Robert J. Peroni The Fondren Foundation Centennial Chair for Faculty Excellence and Professor of Law The University of Texas School of Law Austin, TX

Co-Chair Peter H. Blessing Associate Chief Counsel (International) Internal Revenue Service Washington, DC

Co-Chair Theodore D. Setzer Assistant Deputy Commissioner (International) Internal Revenue Service Washington, DC

A d v i s o r y B o a r d

Page 13: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

13http://www.tggroup.com/GWUIRSInstitute/

REGISTRATION

Registration fee for the two-day International Tax Institute, including two luncheons, conference materials and reception is USD 850.

* Registration fee for Full-time Government employees and Full-time Faculty members at educational institutions: USD 425.

The registration fee includes access to the panel discussion materials prior to the Institute.

Registrations can be processed via the internet at http://www.tggroup.com/GWUIRSInstitute/

Mail: GWU Registration Center, Mance and Associates LLC, 5709 Blair Road, NE, Washington, DC 20011

Fax: 202-747-2723

Customer Service Inquiries ONLY: Please contact Safisha Mance, GW Registrar, at 202-492-8278 or [email protected]. Unfortunately, registrations will not be taken over the phone. Please submit your registration no later than DECEMBER 9, 2019. Registrations received after that date will be processed onsite at the Institute. In that case, attendees should bring their completed registration form to expedite the registration process.

CANCELLATION/REFUND POLICY

Refunds requested in writing will be honored if received by DECEMBER 2, 2019. A USD 250 cancellation fee will apply. No refunds will be made after that date, however, you may send a substitute in your place. Please notify us in advance if you choose to exercise this option. There will be no refunds for no-shows or on-site cancellations.

ACCREDITATION

The Thirty-Second Annual Institute on Current Issues in International Taxation scheduled for December 19 - December 20, 2019 will provide: Delivery Method: Group-Live; panel discussions and lectures by speakers, with limited ability of registrants to ask questions of the speakers.

The George Washington University Law School offers programs at an advanced level of continuing education. Although no prerequisite courses, experience or advance preparation is required to participate in this program, working knowledge of international taxation and some prior knowledge of the program topics are necessary.

This program is structured as a group-live offering (and is not a self-study offering). The recommended number of CPE credits to be awarded is 14.

Learning Objectives: • Foster dialogue between government and private sector panelists and registrants. • Inform registrants of current developments in the international tax area. • Refine and develop future programs in response to registrant comments about topics and speakers.

For more information before the Institute regarding administrative policies, such as complaint, refunds, and cancellation, please contact Safisha Mance, CMP, GWU Law Institute Program Registrar, 5709 Blair Road, NE, Washington, DC 20011, Phone 202-492-8278, Fax 202-747-2723, [email protected]. For assistance after the Institute regarding submission for CPE and/or CLE credit, please contact the GW Law Office of Continuing Legal Education at [email protected].

The George Washington University is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of

G e n e r a l I n f o r m a t i o n

Page 14: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

The Institute 14

CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.

Complaints regarding registered sponsors may be addressed to the: National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417, Web site: www.nasba.org.

Upon request, the Institute will submit applications to state bar associations for continuing legal education credits. Since crediting is decided by the respective state bar authority, no advance assurance can be given that credit will be granted in all cases. Please indicate your interest in CLE or CPE by completing the designated portion of your registration form.

Individuals will be provided a Certificate of Completion reflecting their attendance as evidenced by the completion and verification of Attendance Affidavits maintained by the Institute Monitors.

HOTEL ARRANGEMENTS

The Institute will be held at the JW Marriott Hotel located at 1331 Pennsylvania Ave., NW in Washington, DC 20004. To make your hotel reservation at the JW Marriott, please visit the Institute website at http://www.tggroup.com/GWUIRSInstitute/ or you may call Marriott's toll free number directly, 1-800-393-2503 in the U.S. & Canada, 202-393-2000 from all other

locations. A room block has been created for the Institute, so ask for the George Washington University Law School guest room block.**

The Hotel reservation cut-off date is November 19, 2019 and the room block sells out 2-3 weeks PRIOR to the reservation cut-off date, so make your reservations now.

**Quoted sleeping room rates via the website and the reservation call center reflect the 2018 Government per diem hotel rates as determined by the U.S. GSA. In October 2019, the 2019 Government per diem hotel rate will be published.

TRANSPORTATION

A taxi ride from Ronald Reagan National Airport to the JW Marriott Hotel will take 15-20 minutes and will cost approximately USD 20.00 one way. The Blue Line (towards Largo Town Center) of the Washington Metrorail System departs from this airport and arrives at the Metro Center station, 0.23 miles SW from the JW Marriott Hotel. If you are arriving at Dulles

International Airport, the taxi ride will take about 40-50 minutes and the fare is approximately USD 65.00 one way.

Please visit the Institute website at http://www.tggroup.com/GWUIRSInstitute/ for more details on the hotel, parking and transportation.

QUESTIONS FOR THE IRS AND PANELISTS

You may submit written questions for any of the program panelists in advance. If your wish to do so, please send your written question(s) to [email protected]

UNIVERSITY POLICY ON EQUAL OPPORTUNITY

The George Washington University does not unlawfully discriminate against any person on the basis of race, color, religion, sex, national origin, age, disability, veteran status, or sexual orientation.

Page 15: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

R e g i s t r a t i o n

15

The 32nd Annual Institute on Current Issues in International Taxation Please submit your registration form on/before DECEMBER 9, 2019. All registrations received after DECEMBER 9, 2019 will be processed on-site at the conference.

Please Print Legibly ___ I am a speaker ___ Institute Registrant: USD 850

___ Full-time Government employee or Full-time Faculty member: USD 425

The registration fee includes access to the panel discussion materials prior to the Institute.

First & Last Name ___________________________________________________________________________

Title _______________________________________________________________________________________

Affiliation __________________________________________________________________________________

Address ____________________________________________________________________________________

City ____________________________________ State _______ Zip ________________ Country __________

Office Telephone ______________________________Office Fax ___________________________________

E-mail_______________________________________________________________________________________

l Check here if you require special services. If you are applying for CLE/CPE credit, please provide the following information:

CLE State ____________________ ID# ______________________________________________________

CPE State ____________________ ID# ______________________________________________________

How did you hear about the conference? __l Brochure __l Website _ _l Colleague

R e g i s t r a t i o n

REGISTRATION Mail form to: The GWU Registration Center Mance & Associates, LLC 5709 Blair Road, NE Washington, DC 20011 Fax form to: 202-747-2723

Internet: http://www.tggroup.com/GWUIRSInstitute/ Registration Queries: Unfortunately, registrations will not be taken over the phone. For Customer Service Inquiries ONLY contact Safisha Mance, GW Registrar, at 202-492-8278 or [email protected]

CANCELLATION/REFUND POLICY Refunds requested in writing will be honored if received by DECEMBER 2, 2019. A USD 250 cancellation fee will apply. No refunds will be made after that

date. However, you may send a substitute in your place. Please notify us in advance if you choose to exercise this option.

http://www.tggroup.com/GWUIRSInstitute/

Page 16: 32nd Annual Institute on Current ... - The Gardiner Group 11480-tax brochure (006).… · Kamela Nelan ITC, Attorney-Advisor, U.S. Department of Treasury, Washington, DC Raymond J.

2000

H S

tree

t, N

W

Was

hin

gto

n, D

C 2

0052

h

ttp

://w

ww

.tg

gro

up

.co

m/G

WU

IRSI

nst

itu

te/

Pres

ort

ed

Firs

t C

lass

Mai

l U

.S. P

ost

age

Paid

W

ash

ing

ton

, DC

Pe

rmit

#59

3