You re Invited. Fifth Annual TEI Houston Global Tax Symposium. Thursday, November 2, 2017

Transcription

1 You re Invited Fifth Annual TEI Houston Global Tax Symposium Thursday, November 2, 2017 Hyatt Regency Houston Downtown 1200 Louisiana Houston, Texas United States Event Website >>>

2 Approved for 7.5 CPE credits. Baker & McKenzie North America Tax Practice Group 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 the final authority on the acceptance of individual courses for CPE credit. Approved for 6.5 Illinois and Texas general CLE credits and 7.5 New York areas of professional practice CLE credits. Participants requesting CLE for other states will receive Uniform CLE Certificates. Baker & McKenzie LLP is an Illinois CLE approved provider. Baker & McKenzie LLP has been certified by the New York State CLE Board as an accredited provider in the state of New York and this program may earn newly admitted New York Attorneys credit under Areas of Professional Practice This full-day seminar will cover a wide range of topics relevant to companies operating globally across various industries. Considering recent updates in policy and administration, it will include sessions by leading practitioners on international tax planning and controversy, M&A, transfer pricing, tax treaty and practical BEPS applications, among others. The Symposium aims to provide applicable strategies and informative advice for tax practitioners of all levels facing real-world challenges. We hope to see you there!

3 8:00 am - 8:30 am REGISTRATION AND BREAKFAST 8:30 am - 8:45 am WELCOME Eamonn Bakewell, President, TEI Houston, Chevron Services Company 8:45 am - 10:00 am TAX REFORM AND REGULATORY UPDATE Despite the generally accepted consensus that corporate tax reform is needed to make U.S. companies more competitive and the strong political rhetoric surrounding tax reform, we are nearing the end of 2017 without a certain path forward to enacting comprehensive tax reform legislation (and continued uncertainty about the measuring date for a deemed repatriation tax, if any). As a result, companies are forced to plan in a state of uncertainty and tax departments are being asked questions by their Boards for which only speculative responses can often be made. This panel will address the current state of tax reform, the details of any mainstream proposals, the path towards legislation being enacted and the potential political barriers to same. The panel will also address key regulatory developments. Ujwala Bhandari, ENGIE North America Jonathan Martin, Baker McKenzie, Houston Alexandra Minkovich, Baker McKenzie, Washington DC David Noren, McDermott Will & Emery, Washington DC Jay Singer, McDermott Will & Emery, Washington DC 10:15 am - 11:30 am MULTILATERAL INSTRUMENT/ E.U. DEVELOPMENTS/U.S. TAX TREATIES As BEPS and related anti-avoidance initiatives around the globe move from concept to reality, taxpayers are forced to determine their long-term impacts and respond to the same. Implementation of these initiatives have far-reaching impacts in terms of substance, how taxpayers look at effective tax rates and strategies to manage same, and otherwise. Further, enhanced coordination among tax authorities has impacted the manner in which tax authorities enforce their tax laws and taxpayers think about structuring their operations. This session will highlight the most significant developments in the wake of BEPS, including recent developments involving the Multilateral Instrument (MLI), EU Anti-Tax Avoidance Directive I and II, EU State Aid cases. In addition, the session will touch on recent treaty developments. Emily Whittenburg, Shell Oil Company Susan Stone, Baker McKenzie, Houston Roeland Bavinck, Baker McKenzie, Amsterdam Kristina Novak, McDermott Will & Emery, Dallas Mark Thomas, McDermott Will & Emery, Dallas 10:00 am - 10:15 am BREAK

4 11:30 am - 12:45 pm LUNCHEON PRESENTATION The future of energy markets will continue to be shaped by supply-demand fundamentals, environmental policy, technology, and, intersecting with it all, geopolitics. But, the status quo paradigm is changing. Developing Asian countries now are the principal antagonists, while the developed economies of the OECD are increasingly becoming less relevant as drivers of change. The implications are far reaching, and will resonate for generations. Speaker: Dr. Kenneth B. Medlock III, Baker Institute 12:45 pm - 1:00 pm BREAK 1:00 pm - 2:00 pm TAX PLANNING IN A CbCR WORLD OF INCREASED TRANSPARENCY The Country-by-Country Reporting regime has been nearly universally accepted by tax authorities around the globe. What does this mean for the evolving world of tax compliance and international tax planning? Where are MNEs feeling pressure from on these issues? How will these changes affect cross-border tax compliance, planning and controversy for MNEs? How can MNEs navigate this changing landscape? Join us for a discussion on adapting to the new International Tax landscape and the increased transparency it provides for tax authorities. Walt Stone, Solvay 2:00 pm - 3:00 pm UPDATE ON REPATRIATION STRATEGIES AND CONTROVERSY DEVELOPMENTS The demands on treasury and tax groups to repatriate offshore cash continue to be significant. As such, taxpayers must consider repatriation planning for the remainder of 2017 and beyond, particularly in light of potential tax reform. From a planning perspective, the panelists will explore planning alternatives, IRS guidance, and relevant case law that must be considered in structuring tax transactions. From a controversy perspective, the panelists will discuss topics related to the deference to IRS guidance, statute of limitations issues, and the IRS s increased reliance on non-statutory sources, including legislative history, policy concerns, and judicial doctrines such as substance over form and economic substance. This panel will also address the IRS s increased focus on repatriation strategies through its recently unveiled Campaign approach. Janet Rudnicki, SCI Julia Skubis Weber, Baker McKenzie, Chicago Kai Kramer, Baker McKenzie, Houston Damon Lyon, McDermott Will & Emery, Chicago Andrew Roberson, McDermott Will & Emery, Chicago 3:00 pm - 3:10 pm BREAK Angela J. Walitt, Baker McKenzie, Washington DC Jessie Coleman, Baker McKenzie, Washington DC Cym Lowell, McDermott Will & Emery, Dallas Mike Louis, McDermott Will & Emery, Dallas

5 3:10 pm - 4:00 pm MAINTAINING CONFIDENTIALITY WHILE NAVIGATING CROSS-BORDER TRANSACTIONS 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 use of treaty requests to bypass U.S. safeguards against disclosure, as well as taxpayers rights and defenses under a treaty request. Mickey Culpepper, Baker Hughes, a GE Company Robert Albaral, Baker McKenzie, Dallas Susan E. Ryba, Baker McKenzie, Chicago Laura Gavioli, McDermott Will & Emery, Dallas Denise Mudigere, McDermott Will & Emery, Dallas 4:00 pm - 5:15 pm Treasury Center/Currency Issues This panel will discuss cash pooling and treasury centers issues under the section 385 regulations and currency issues, including subpart F, section 988(d) and section 987 issues. Susan Musch, Sasol Rafic Barrage, Baker McKenzie, Washington DC Joshua Richardson, Baker McKenzie, Chicago Kristen Hazel, McDermott, Will & Emery, Chicago Michael Wilder, McDermott Will & Emery, Washington DC 5:15 pm - 5:30 pm CLOSING REMARKS 5:30 pm - 6:30 pm Networking Reception

6 Registration and Parking Tax Executives Institute Houston Global Tax Symposium Thursday, November 2, 2017 Registration & Breakfast: 8:00 am 8:30 am Plenary Panel Program & Luncheon: Networking Cocktail Reception: Hyatt Regency Houston Downtown 1200 Louisiana Houston, Texas United States 8:30 am 5:30 pm 5:30 pm 6:30 pm To register and reserve your place please visit: TEI Members: US$100 Non-Members: US$125 Parking: Complimentary validation will be provided at registration. To map the hotel, please click here. For more information or if hotel accommodations are needed, please contact: Esther Stone William J. A. Moore