Friday , January 19, 2007
8:30AM – 10:30AM

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

8:30 AM
Opening Remarks by the Chair

8:35 AM
Important Current Issues under Subpart F. This panel will provide a detailed analysis of Subpart F, including a examination of the practical application of the "look-through" rule under Section 954(c)(6), and a discussion of the proposed regulations under ections 959 and 961.

Moderators:  Carol Tello, Sutherland Asbill & Brennan LLP, Washington, DC, and Lowell Yoder, McDermott Will & Emery, Chicago, IL

Panelists:  Steven Musher, Associate Chief Counsel (International), IRS, Washington, DC; John Harrington, Deputy International Tax Counsel, Department of Treasury, Washington, DC

9:35 AM
Emerging International Merger and Acquisition Issues.  This panel will discuss current guidance regarding international tax-free mergers and acquisition transactions including the transfer of intangibles, the treatment of cross-border cash “D” reorganizations and significant issues with respect to gain recognition agreements.

Moderator: Nardi Bress, PriceWaterhouseCoopers LLP, Washington, DC

Panelists: Joe Calliano, Grant Thornton LLP, Washington, DC; Danielle E. Rolfes, Ivins Phillips & Barker Chartered, Washington, DC; Hal Hicks, International Tax Counsel, Department of Treasury, Washington, DC; Michael DiFronzo, Office of the Associate Chief Counsel (International), IRS, Washington, DC

10:30 AM – Noon
Joint Session of FAUST / FLF / Transfer Pricing / USAFTT – Panel on ImportantDevelopments.

Moderator: Margie Rollinson, Ernst & Young LLP, Washington, DC

Panelists: Nicholas J. DeNovio, Latham & Watkins LLP, Washington, DC; Gideon Alpert, Alston & Bird LLP, New York City; Darrin Litsky, Deloitte & Touche LLP, New York City; Hal Hicks, International Tax Counsel, Department of Treasury, Washington, DC

Noon – 1:30 PM
FAUST Luncheon and Business Meeting followed by a Luncheon Speech on the Prospect for International Tax Reform

Guest Speaker: Robert Dilworth, Deputy Assistant Treasury Secretary, Department of Treasury, Washington, DC

7:30 PM –
Joint International Tax Committees Dinner – Chima Steakhouse (Ft. Lauderdale, FL)

Details:  $85 / person.  Contact Jeffrey Rubinger of Holand & Knight LLP at jeff.rubinger@hklaw.com