February 21, 2019

Deciphering the New International Tax Regime

Plenary sessions addressing the new strategic planning picture, featuring:

  • Fearless Regulatory and Legislative Prognostications
    Michael Caballero, Covington
    Ed McClellan, Covington

  • Global Picture: U.S. Tax Reform in Context
    Robert Long, Covington
    John Veroneau, Covington
    Samuel Maruca, Covington, Moderator

  • The Real World: How Companies are Coping with Implementation
    A distinguished panel of senior tax executives, including:
    Patrick Brown, GE
    Louise Weingrod, Johnson & Johnson
    Jamey Shachoy, Accenture
    Robert Culbertson, Covington, Moderator

Breakout Sessions

The breakouts are meant to provide a forum for discussing strategies to manage and reduce exposure to the new regimes, including how to address difficult interpretive issues under the legislation and how to manage disputes with the IRS (and accounting firms). The sessions will start with an introduction from Covington, followed by a moderated discussion among session participants.

Session I 

  • BEAT, Section 163(j), and Other Limits
    This session will address BEAT, section 163(j), and other deduction limitations—not just for inbound.

  • GILTI Until Proven Innocent
    This session will explore the game-changing impact of GILTI on CFC structures (see Session II for the potential benefits of GILTI’s friendlier cousin FDII).

  • Global Audit and Transparency
    Participants will discuss strategies and best practices for defending transfer pricing structures after BEPS Action 13 and the revisions to the OECD transfer pricing guidelines.

  • Hot Topics for Professional Sports
    Participants will discuss the valuation of player contracts and new strategies for international media and licensing transactions.

Session II 

  • IP Planning: Whether and How
    Participants will discuss current trends among multinational enterprises in the positioning of their IP, with particular attention to the impact of FDII and other changes to the U.S. rules, as well as BEPS.

  • Previously Taxed Income: 31 Flavors
    In a post-deferral world, managing PTI and associated credits will be a critical task; this panel will explore the many variants of PTI, including semi-taxed PTI and, yes, untaxed PTI.

  • Taking Sustainable Positions (That Do Not Blow Up Your ETR)
    Because many provisions of the TCJA are unusually inscrutable, disputes over their meanings are already percolating, and Treasury guidance will not necessarily answer all questions. This session will consider how to navigate ambiguities and inconsistencies in the rules, including preparation for controversy.

Following the conference, we will be hosting dinner for those who are able to join us.

Event Location: 
Covington The New York Times Building 620 Eighth Avenue New York, NY 10018