The 2011 OECD International Tax Conference: OECD-U.S. Business Dialogue on International Tax Washington, DC June 6-7, 2011

Similar documents
` The 2010 OECD International Tax Conference: OECD-U.S. Business Dialogue on International Tax Washington, DC June 7-8, 2010

USCIB Taxation Committee

Wednesday, February 24, 2010

The OECD s Evolving Role in Shaping International Tax Policy

FMS REGIONAL CONFERENCE June 7 9, 2017

IMF Revenue Mobilizations and Development Conference: Session on Business Taxation. Alan Carter (ITD) Washington DC, April 18, 2011

OECD meets with business on base erosion and profit shifting action plan

Principles of International Tax Planning

Session Report: US Model Treaty 2015 Proposals

Revenue s Role in the Quest for Inclusive Development: What Works and What Can Work Better? South-South Sharing of Successful Tax Practices (S 4 TP)

International Taxation of Income from Cross-Border Services

2 nd JOINT WCO/OECD CONFERENCE ON TRANSFER PRICING AND CUSTOMS VALUATION TRANSFER PRICING, INDIRECT TAXES AND VAT: EXPLORING POSSIBLE CONVERGENCES

OECD s Forum on Tax Administration agrees on BEPS implementation, digital and capacity building

Proposed Regulations Relating to the Foreign Account Tax Compliance Act (FATCA).

International Family Forum Managing Change April 19, 2017 Moderator: Drake Jackman, CFA, TEP Managing Director - International Wealth Management

Hong Kong s OECD BEPS Associate status requires implementation of BEPS minimum standards

OECD launches International Compliance Assurance Programme pilot

International Dispute Resolution: Global Perspectives and Opportunities GW-IRS Annual Tax Institute Washington, DC November 30, 2017

September 25, Request for Clarification on Regulation Number PER-10/PJ/2017 and Director General of Taxation Forms DGT-1 and DGT-2

On behalf of the European Private Equity and Venture Capital Association (EVCA)

Transfer Pricing in the Age of Transparency, Innovation, and Transformation

April 4, The Honorable Douglas H. Shulman Commissioner Internal Revenue Service 1111 Constitution Ave., NW Washington, DC 20224

VI. Permanent Establishments and Profit Attribution to Permanent Establishments

Fixed Income Conference

Transfer Pricing Developments

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

Seminar Report: Building Capacity to Implement the IGF s Mining Policy Framework in Mongolia. March 20 23, 2017

India releases Annual Report covering transfer pricing and international tax developments

Planning for Intangible Property Migration in an Uncertain Environment. ABA Section of Taxation Mid Year Meeting January 25, 2013

hrs Registration hrs Inaugural Session OECD Action Plan Progress on BEPS and Implications. Welcome Remarks

Economic and Social Council Special Meeting on International Cooperation in Tax Matters (ECOSOC Chamber, 7 April 2017) Tentative Programme

STEP INTERNATIONAL TAX AND ESTATE PLANNING FORUM

Economic and Social Council Special Meeting on International Cooperation in Tax Matters (ECOSOC Chamber, 18 May 2018) Tentative Programme

BEPS Action 14: Make Dispute Resolution Mechanisms More Effective

STEP INTERNATIONAL TAX AND ESTATE PLANNING FORUM

Global Tax Alert. OECD releases report under BEPS Action 13 on Transfer Pricing Documentation and Country-by-Country Reporting.

May 26, 2015 Harvard Club of NYC

Current Work of Interest to Developing Countries. Michelle Levac Chair Working Party 6

ICI Mutual Insurance Company, RRG RISK MANAGEMENT CONFERENCE April 6-8, 2016 Windsor Court Hotel New Orleans, Louisiana FINAL AGENDA

U.S. TRANSFER PRICING PRIMER June 11 & 12, 2015 Fairfax Embassy Row Washington, DC

Tax Aspects of International Joint Ventures June 9 & 10, 2014 Houston, TX Gardere Wynne Sewell Conference Center

ABA Section of Taxation Transfer Pricing Committee Panel APMA: Past, Present and Future May 10, 2013 Washington, DC

Consequences Of EU's Belgium Tax Scheme Decision

OECD Update. OECD Tax Agenda Overview

SMU-TA CET CONFERENCE FUTURE OF TAXES IN DISRUPTIVE TIMES 17 August 2017

2015/FDM1/001. Draft Agenda. Purpose: Consideration Submitted by: Chair

Malaysian Budget Conference 2017

Ref: PSA/WP/DO(2012)32 06 February Dear Alex,

2018 JOINT TE/GE COUNCIL EMPLOYEE PLANS & EXEMPT ORGANIZATIONS ANNUAL MEETING. University of Baltimore Baltimore, Maryland February 22-23, 2018

Protecting the Tax Base of Developing Countries: An Overview

31st annual Federal Tax Institute

AUTOMATIC EXCHANGE OF INFORMATION CONFERENCE

IRS issues guidance on treatment under Sections 482 and 901 of transactions with foreign branches or disregarded entities

Initial Observations of the Working Group on U.S. RMB Trading and Clearing April 5, 2016

EU STATE AID. An International Tax Perspective. Wednesday, December 7, :00 p.m. 5:00 p.m. GMT

5TH ANNUAL NEW YORK CITY REINSURANCE CONFERENCE

IRS Large Business & International Division Issues Transfer Pricing Guidance

IBFD 7th International Tax Lecture

Manal Corwin International Tax Counsel United States Department of the Treasury 1500 Pennsylvania Ave. NW

International Conference on Financial Education. Taking Financial Literacy to the Next Level: Important Challenges and Promising Solutions

Chairman: Members: Professor Eric M. Zolt

IV Tax Administration in the Era of Globalization

Current priority areas for BIAC

Tax Management International Journal TM

Comparability and Economic Adjustments

PREMIER INTERNATIONAL TAX LIBRARY ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::

United Kingdom diverted profits tax now in effect

Fourth Annual High-Level Anti-Corruption Conference for G20 Governments and Business AGENDA. 11 June 2014 Rome, Italy

Tenth Annual ICC New York Conference

STEP INTERNATIONAL TAX AND ESTATE PLANNING FORUM

March 30, Request for Comments on Form 8802, Application for United States Residency Certification

AUTOMATIC EXCHANGE OF INFORMATION CONFERENCE

FOURTH MEETING OF THE OECD FORUM ON TAX ADMINISTRATION January Cape Town Communiqué 11 January 2008

Australian government introduces bill to combat multinational tax avoidance

An Update on OECD Transfer Pricing Developments and Proposals for the Taxation of Intangibles

KEYNOTE SPEAKER S PROFILE. Professor Surya Subedi, University of Leeds

The OECD s Discussion Draft on Transfer Pricing Documentation and Country-by-Country Reporting: A work in progress

Day 2: Session 1 Transforming today for the challenges of tomorrow

Australian Taxation Office Issues Guidance on APAs

Tax Certainty EBF TAX CONFERENCE Brussels, 22 November Giorgia Maffini. OECD s Centre for Tax Policy and Administration

Based on the current Foreign Account Tax Compliance Act (FATCA) effective date of July 1, 2014, financial institutions have less than 90 days to:

Tax Alert Canada. Teletech decision exposes potential pitfalls in obtaining double tax relief. Background

G8/G20 TAXATION ISSUES : Tax Training Day, ODI, London 16 September 2013

IRS/Tax Practitioners Symposium Illinois CPA Society BONUS SESSION!

OECD releases final BEPS package

Council of the EU reaches an agreement on new mandatory transparency rules for intermediaries and taxpayers

SMU-TA CET CONFERENCE FUTURE OF TAXES IN DISRUPTIVE TIMES 17 August 2017

Inbound Developments. Your panel

Presentation by Shigeto HIKI

Japan and Chile sign income tax treaty

Advanced Course in Transfer Pricing JUNE 2014

An unprecedented gathering of the most prominent international authorities in accounting today.

Tax & Legal Weekly Alert

Welcome Remarks by Chairman of Organising Committee, Mr Jeffrey Chan Wah Teck, SC

SPONSORSHIP INVITATION

OECD issues Action Plan on Base Erosion and Profit Shifting (BEPS)

China s SAT issues new rules on reporting of related-party transactions and contemporaneous documentation

TRANSFER PRICING AND INTANGIBLES: SCOPE OF THE OECD PROJECT

SMU-TA CET CONFERENCE FUTURE OF TAXES IN DISRUPTIVE TIMES 17 August 2017

Fourth OECD G20 High-Level Conference on Corruption: Governments and Business DRAFT AGENDA. 11 June 2014 Rome, Italy

Transcription:

` The 2011 OECD International Tax Conference: OECD-U.S. Business Dialogue on International Tax Washington, DC June 6-7, 2011 Day One 1:00 1:30 p.m. Registration I. Welcome 1:30 2:00 p.m. Karen Kornbluh, U.S. Ambassador and Permanent Representative to the OECD [invited] Charles P. Heeter Jr., Chairman, BIAC; and Managing Director, Deloitte Touche Tohmatsu II. Opening the Dialogue for 2011: Tax Reform, Growth and Competitiveness 2:00-3:15 p.m. Major Tax Trends and Developments including Tax Reform and Competitiveness The United States corporate statutory rate is among the highest in the world: what does this mean for competitiveness? Should the rate come down? How can that be accomplished in a deficit driven environment? What are the implications of tax reform for multinational corporations? Jeffrey Owens, Director, OECD Centre for Tax Policy & Administration Thomas Barthold, Chief of Staff, Joint Committee on Taxation Manal Corwin, Deputy Assistant Secretary for International Tax Affairs, U.S. Treasury Philip West, Partner, Steptoe & Johnson LLP 1

III. The OECD Looking Beyond Its Borders 3:15 4:15 p.m. Enlargement, Engagement with Non-OECD Economies and the New Focus on Tax and Development The myth of the OECD as an insular rich man s club is being shattered daily as the organization absorbs a wave of new members, deepens its engagement with other major new economies, and sharply increases its focus on issues relating to tax and development. In this session, panelists will analyze these developments and their significance to business. Their discussion will touch on: how a more inclusive dialogue among nations will affect the OECD s standard-setting role; what the impact on business will be of strengthening the capacity of tax administrations around the the world; what the response should be to the calls by NGOs and development agencies for the introduction of country-by-country reporting requirements on multinational corporations. Chris Lenon, Group Strategic Adviser, Tax Policy, Rio Tinto plc and Taxation Committee Chair, BIAC John Bartlett, Group Head of Tax, BP plc Masatsugu Asakawa, Deputy Vice Minister for International Affairs, Ministry of Finance, Japan and Chair-Elect, OECD Committee on Fiscal Affairs Grace Perez-Navarro, Deputy Director, OECD CTPA David McNair, Senior Economic Justice Advisor, Christian Aid 4:15-4:30 p.m. Break IV. Permanent Establishments 4:30-6:00 p.m. OECD Update on High Profile PE Issues Permanent establishment issues keep tax directors and practitioners up at night because the consequences of being wrong on this issue are so dramatic. The OECD is working on revising the commentary to Article 5 to address a number of these thorny issues. What is the proper treatment of commissionaire arrangements, what are the implications of using subcontractors and when are premises at the disposal of an enterprise, in particular where employees of one company work in the premises of a related company? This panel will provide insight into current thinking on these and other timely permanent establishment issues. Jacques Sasseville, Head of Tax Treaty Unit, OECD Jesse Eggert, Associate International Tax Counsel,U.S. Treasury Gary Sprague, Partner, Baker & McKenzie LLP David Sutherland, Chief Financial Officer in Asia Pacific, Morgan Stanley 6:00 7:30 p.m. Reception

Day Two 8:00 8:30 a.m. Continental Breakfast V. Global Tax Administration 8:30-9:30 a.m. A Conversation with Steven Miller, Deputy Commissioner, Services and Enforcement, IRS Steven Miller, Deputy Commissioner for Services and Enforcement at the IRS, will share his views on the major challenges in tax administration today and on the initiatives the OECD s Forum on Tax Administration (FTA) is taking to improve taxpayer service and compliance. Steven Miller, Deputy Commissioner, Services and Enforcement, IRS Bill Sample, Corporate Vice President, Worldwide Tax, Microsoft Corporation and Taxation Committee Chair, USCIB VI. Improved International Tax Cooperation 9:30-10:30 a.m. MNE Guidelines and Improving Tax Compliance The OECD is revising its Guidelines for Multinational Enterprises which were last revisited in 2000. The new Guidelines on tax may adopt a new spirit of the law concept which may guide compliance with tax filing obligations. The OECD has also recently released a report on Tackling Aggressive Tax Planning Through Improved Transparency and Disclosure. Countries are looking for more selfregulation by taxpayers, more and earlier information from taxpayers, and more cooperation between countries. How will these initiatives affect multinational corporations? Grace Perez-Navarro, Deputy Director, OECD Michael Danilack, Deputy Commissioner (International) LB&I, IRS Marcos Vinicius Neder, Partner, Baker & McKenzie and Former Undersecretary, The Brazilian Federal Revenue Department Steven Bunson, Head of Global Tax, Goldman, Sachs & Co. 10:30-10:45 a.m. Break 3

VII. 10:45 a.m.-12:00 p.m. Developments in Treaty Implementation Withholding Issues including the OECD s "TRACE" (Treaty Relief and Compliance Enhancement) Project The OECD, through its Treaty Relief and Compliance Enhancement (TRACE) project, is now more than five years into the development of a standardized system through which countries could offer streamlined procedures for claiming reduced treaty rates of withholding tax on portfolio investment income and could obtain improved information reporting about the recipients of that income. What are the implications of the proposed system for investors, financial intermediaries and governments? How will it change the landscape for obtaining treaty relief internationally? How will it interact with other initiatives, such as the IRS s FATCA? Mary Bennett, Head of Tax Treaty & Transfer Pricing Division, OECD Michael Plowgian, Attorney Advisor, U.S. Treasury Philip Garlett, Partner, Burt, Staples & Maner LLP Paul Radcliffe, Director, EMEA Corporate Tax, Citigroup, Inc. 12:00-1:30 p.m. Luncheon Keynote Speech VIII. OECD Work on Transfer Pricing and Intangibles 1:30-2:45 p.m. Definitional Issues, Transfer of Intangibles, and Issues of Legal Versus Economic Ownership The OECD is just beginning a multi-year effort to deal with transfer pricing issues related to intangibles. What exactly is an intangible? What are the possible approaches and relevant factors to defining intangibles? Should notions such as goodwill, locational advantages, network intangibles and others be considered intangibles for transfer pricing purposes? When do employee assignments lead to the transfer of intangibles? What are the situations where an entity should at arm s length be entitled to share in the return of an intangible? What is the meaning and relevance of economic ownership, equitable ownership and other similar notions? The panel will address these issues. David Ernick, Associate International Tax Counsel, U.S. Treasury Michelle Levac, Transfer Pricing Specialist, Canada Revenue Agency and Chair, OECD s Working Party 6 on the Taxation of Multinational Enterprises Bill Sample, Corporate Vice President, Worldwide Tax, Microsoft Corporation and Taxation Committee Chair, USCIB Alan Granwell, Partner, DLA Piper 2:45-3:00 p.m. Break

IX. OECD Work on Transfer Pricing and Intangibles (continued) 3:00-4:15 p.m. Valuation of Intangibles If an intangible is transferred, how should the transfer price be determined? What is the relevance for valuing intangibles of the recognized transfer pricing methods? What is the relevance for transfer pricing purposes of financial valuation methods based on a market approach, a cost approach, or an income approach? How can the reliability of the application of forward-looking methods such as the Discounted Cash Flow analysis be assessed? Are forward-looking methods administrable for the taxpayer and for the tax authority? The panel will address these concerns. Michael McDonald, Financial Economist, U.S. Treasury Chris Faiferlick, Principal, Ernst & Young LLP David P. Lewis, Vice President Global Taxes, Chief Tax Executive and Assistant Treasurer, Eli Lilly & Co. X. Ask the OECD 4:15-4:55 p.m. Your Opportunity to Ask the Questions on Your Mind Jeffrey Owens, Director, OECD Centre for Tax Policy & Administration Grace Perez-Navarro, Deputy Director, OECD CTPA Mary Bennett, Head of Tax Treaty & Transfer Pricing Division, OECD Jacques Sasseville, Head of Tax Treaty Unit, OECD XI. Conclusions 4:55-5:00 p.m. Summing Up Jeffrey Owens, Director, OECD Centre for Tax Policy & Administration Carol Doran Klein, Vice President and International Tax Counsel, USCIB 5