Friday, October 20

3:30PM - 5:30PM

Foreign Activities of US Taxpayers

Chair:  Giovanna Sparagna, Sutherland Asbill & Brennan LLP, Washington, DC

3:30pm             Opening Remarks by the Chair. 

3:35pm             Mission Impossible III: Understanding Current Cross-Border M&A Issues. This panel will discuss current guidance regarding cross-border tax-free mergers and acquisition transactions. The panel will use a case study format to explore the tax results of these transactions including their impact on corporate attributes. Moderator: Peter H. Blessing, Shearman & Sterling LLP, New York, NY.  Panelists: Hal Hicks, International Tax Counsel, Department of Treasury, Washington, DC; John Merrick, Office of Chief Counsel (International), Washington, DC; Michael DiFronzo, McDermott Will & Emery, Chicago, IL; Kimberly Majure, Miller & Chevalier, Washington, DC; Steven Surdell, Ernst & Young LLP,  Chicago, IL.

4:35pm             The Chronicles of Current Branch Transaction Guidance/Other Emerging Issues in Subpart F.  This panel will provide a detailed analysis of the treatment of foreign branch transactions including a review of the re-proposed section 987 regulations. Time Permitting, the panel will also explore the practical application of the "look-through" rule under 954(c)(6).  Moderator: Scott Farmer, McKee Nelson, Washington, DC.  Panelists: Jeff Dorfman, Branch Chief, Office of Associate Chief Counsel (International), IRS, Washington, DC; John Merrick, Office of Chief Counsel (International), IRS, Washington, DC; Chip Harter,  PriceWaterhouseCoopers, Washington, DC; David Golden, Ernst & Young LLP, Washington, DC.