8:30am   Opening Remarks by the Chair.

8:35am   Cross-Border Mergers and Acquisitions Part 1. This panel, the first of a doubleheader 
on cross-border M&A developments, will first address the uncertainties in dealing with the GRA (gain recognition agreement) provisions under section 367, the effect of  recently issued Notice 2005-74 and anticipated new guidance.  The panel next will discuss section 7874 (inversion) developments, including forthcoming regulations.  Moderator: Nardi Bress, PricewaterhouseCoopers LLP, Washington, DC. Panelists: Janessa  Griffin, Seyfarth Shaw LLP, Chicago IL; David Forst, Fenwick & West LLP, Palo Alto,CA; Hal Hicks, International Tax Counsel, Treasury, Washington, DC; John Merrick,Special Counsel, Associate Chief Counsel (International), IRS, Washington, DC.

9:35am   Cross-Border Mergers and Acquisitions Part 2.  This panel will continue the discussion of cross-border M&A developments.  Additional topics focused on are expected to include developments in respect of the cross-border merger regulations, the proposed regulations addressing section 304 in the context of section 367, the application of Notice 2004-83 (cash "Ds") in a cross-border context, the impact of FTC developments on internal restructurings, etc.  Moderator: Joseph Calianno, Grant Thornton LLP, Washington DC. Panelists: Mark Harris, Ernst & Young LLP, Washington, DC; Hal Hicks, International Tax Counsel, Treasury, Washington, DC; John Merrick, Special Counsel, Associate Chief Counsel (International), IRS, Washington, DC; Josh McKniff, GE Commercial Finance Real Estate, Stamford, CT.