Current International Tax Developments.
This program will address, with shop talk, recent developments in the international tax arena. Topics will include the reproposed ocean, space and communications income sourcing regulations, the latest transfer pricing developments, treaty developments, and areas of new and anticipated guidance including in respect of DCLs, global dealing, section 1446, FTCs, section 959, and section 987. Moderator: David Arroyo, Merrill Lynch Global Tax, New York, NY. Panelists: Alan Dixler, McElroy, Deutsch, Mulvaney & Carpenter LLP, Morristown, NJ; Frédéric Feyten, Nauta Dutilh, Luxembourg; Hal Hicks, International Tax Counsel, Treasury, Washington, DC; Steven Musher, Acting Associate Chief Counsel (International), IRS, Washington, DC; John Warner, Buchanan Ingersoll PC including the law firm Silverstein and Mullens, Washington, DC.