Jul

    Virtual 2020 May Tax Meeting: International Day 2

    1 PM EDT

    Two 90-minute panels: Transfer Pricing committee panel on litigation of transfer pricing cases, followed by a Foreign Activities of U.S. Taxpayers committee current developments panel. See below for panel details.

    Select your state to learn more about the credit details and status of CLE application. Credit is not available for states not listed.

    3.00 total credit hours including

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      07/01/2023

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      07/01/2023

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      07/01/2023

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      07/01/2023

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      07/01/2022

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      3.00 credit hours

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      07/01/2023

    3.60 total credit hours including

    • General

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      Applied for

      3.60 credit hours

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      07/01/2023

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      07/01/2023

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      07/01/2023

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      12/31/2020

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    • General

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      07/01/2023

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    • General

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      Approved

      3.50 credit hours

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      07/01/2023

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      07/01/2023

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      07/01/2023

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      07/01/2022

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      07/01/2023

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    • General

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      07/01/2023

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      10/30/2020

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      07/01/2025

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    Transfer Pricing 1:00 PM - 2:30 PM
    Transfer Pricing Litigation Today. Transfer pricing cases continue to crowd the courts and increasingly produce decisions with ramifications well beyond transfer pricing... and even tax. This panel will analyze and debate the procedural, substantive, and policy dimensions of recent transfer pricing decisions and pending cases. Our panelists will explore the intersection of tax law, administrative law, and litigation procedure in cases such as Altera, Amazon, Facebook, and 3M, critically examining the taxpayer's and the government's positions and identifying their strengths, weaknesses, and broader implications.

    Panelists:
    Sean M. Akins, Partner, Covington
    Kristin Hickman, Distinguished McKnight University Professor, Harlan Albert Rogers Professor in Law, Associate Director Corporate Institute, University of Minnesota Law School
    Joshua Wu, Deputy Assistant Attorney General, U.S. Department of Justice
    Amanda M. Leon, Moderator, Associate at Caplin & Drysdale, Chartered

    Foreign Activities of US Taxpayers 2:30 PM – 4:00 PM
    Current Events Panel: Oh! The Places Your Attributes Will Go. This panel will discuss new international/cross-border regulations or guidance, including the Final Regulations under section 245A, and their effect on cross-border transactions. We will focus on cross-border 304s, revisiting old and cold and hot topics that arise in transactions involving sales of non-US stock to related parties, including basis, earnings and profits, and PTEP.

    Panelists:
    Devon Bodoh, Weil, Gotshal & Manges LLP (Moderator)
    Amie Colwell Breslow, Jones Day, Washington, DC
    Darin Zywan, KPMG LLP

    Event Details

    Format

    Web

    Date

    Jul 02, 2020

    2020-07-02T13:00:00-04:00 2020-07-02T16:00:00-04:00 Virtual 2020 May Tax Meeting: International Day 2

    Two 90-minute panels: Transfer Pricing committee panel on litigation of transfer pricing cases, followed by a Foreign Activities of U.S. Taxpayers committee current developments panel. See below for panel details.

    Sponsors

    Section of Taxation

    MCLE Information

    The ABA will seek 3.0 CLE credit hours in 60-minute-hour states, and 3.6 CLE credit hours in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.

    CPE Information

    The American Bar Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors for Group Live programs (live in-person). State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Due to the COVID-19 crisis, many State boards of accountancy are providing flexibility in the instructional delivery method and allowing for Group Live approved providers to issue credits for Group Live Internet Based vended programs. Kansas does not allow for this flexibility, and waiver requests are pending with Iowa, New York, and North Dakota. All other State boards of accountancy have noted their flexibility. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www. learningmarket.org. Recommended CPE Credits and Fields of Study: Program attendees can earn up to 3.0 CPE credits in Tax. There are no prerequisites.

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