1:30pm   Planning Cross Border Transactions in Light of Section 7874.  The panel will discuss how Section 7874 has affected planning for cross-border transactions caught in the anti-inversion rules, including strategies to avoid the creation of an "expatriated entity" with emphasis on Canadian income trusts. In addition, new regulations under section 7874 are anticipated, and the panel will discuss those regulations and other guidance issued prior to the meeting. Moderator: David G. Shapiro, Dechert LLP, Philadelphia, PA. Panelists: Jack Bernstein,  Aird & Berlis, Toronto, ON; Peter A. Furci, Debervoise & Plimpton LLP, New York, NY; Jefferson VanderWolk, Special Counsel to the Associate Chief Counsel  (International), IRS, Washington, DC.

2:30pm   State Taxation of Inbound Investors -- What You Don''t Know Can Harm You.  Too often, cross-border tax plans focus on taxation at national levels in the country of residence, intermediary countries, and the U.S. State and local tax issues are addressed at the last minute, if at all. The panel will address how state and local tax issues may significantly affect projected profitability. Moderator: Alvan Bobrow, of Hodgson Russ LLP, New York, NY.  Panelists: Carolyn Lee, Roberts & Holland LLP, New York, NY; John P. Barrie, Bryan Cave LLP, Washington, DC; Patrick Martin, Procopio, Cory, Hargreaves & Savitch LLP, San Diego, CA.