ABA Section of Taxation to discuss tax reform and planning during meeting in Washington

WASHINGTON, May 5, 2017 — The impact of tax reform on U.S. multinationals, common cross-border issues in mergers and acquisitions and U.S. tax reform in international tax planning will be among the topics discussed by high-level government officials, judges, corporate counsel and private practitioners during the American Bar Association’s Section of Taxation May Meeting, May 11-13 in Washington, D.C. 

What:  
Section of Taxation May Meeting
Sponsored by the ABA Section of Taxation

When: 
May 11-13, 2017

Where:
Grand Hyatt Washington
1000 H Street, NW
Washington, DC  20001-4520

Mark A. Prater, deputy staff director and chief tax counsel, U.S. Senate Committee on Finance will serve as keynote speaker during the luncheon and plenary session on Saturday at noon.

Program highlights include:

“Common Cross-border Issues in M&A and Tax Planning” — This panel will provide an introduction to key concepts in international taxation, such as withholding tax issues, potential inversions under section 7874, added restrictions on tax-free status under section 367 and debt-equity concerns under the section 385 regulations. The panel will explore hot topics and discuss how newer attorneys can add value in common cross-border transactions. Speakers are Lori A. Hellcamp, Jones Day, Washington, D.C.; Philip R. Hirschfeld, Ruchelman PLLC, New York, N.Y.; and Amit Sachdeva, EY, Houston, Texas.

Thursday, 1:45 – 2:45 p.m.

“Impact of Tax Reform on U.S. Multinationals”— Following the election in November, tax reform has become a high priority for the Trump Administration and the Congress. The House Tax Reform Blueprint, the Senate Finance Working Group Report and other tax reform proposals are possible alternatives that could have significant implications for U.S. taxpayers operating abroad. This panel will be presented in two parts. Part I will address current tax reform proposals and Part II will focus on the impact of potential tax reform proposals on various industries.

Panelists include Barbara M. Angus, chief tax counsel (Majority Staff), House Ways and Means Committee, Washington, D.C.; Kara A. Getz, chief counsel (Minority Staff), House Ways & Means Committee, Washington, D.C.; Ryan Abraham, senior tax counsel, Business and International (Minority Staff), Senate Committee on Finance, Washington, D.C.; Mark A. Prater, deputy staff director and chief tax counsel (Majority Staff), Senate Committee on Finance, Washington, D.C.; and  Viva Hammer, legislative counsel, Joint Committee on Taxation, Washington, D.C. 

Friday, 8:30 – 10:30 a.m.

“‘Destroying’ the Johnson Amendment and the Future of 501(c)(3) Politicking” — President Trump has promised to “totally destroy” the Johnson Amendment, which states that section 501(c)(3) organizations may “not participate” in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidates for public office.” How might he and his allies do that, what would the implications be, and how likely is it that something will actually happen? Panelists are Amanda Tyler, Baptist Joint Committee for Religious Liberty, Washington, D.C.; and John Van Drunen, Evangelical Council for Financial Accountability, Winchester, Va.

Friday, 11:15 a.m. – 12:30 p.m.

“Tax Reform and Real Estate: What to Expect When You’re Expecting” — This panel will discuss pending tax reform legislation with a view on how it will affect real estate ownership and operations. Panelists include Victoria Glover, tax advisor, House Ways & Means Committee, Washington, D.C.

Friday, 3:45 – 4:30 p.m.

“Tax Planning Under the Tax Reform Act of 2017” — Tax planning will obviously change as a result of tax reform legislation. This session is a “nuts and bolts” session describing the new kinds of tax planning that might be available under pending tax reform proposals. These proposals currently include a domestic cash flow tax without interest deductions; a destination- based cash flow tax; a dividends paid deduction; and different tax rates on individuals, pass-throughs and corporations. The focus will be on changes in tax planning for M&A transactions, and internal structuring to maximize the benefits of tax reform.

Saturday, 8:45 – 10:45 a.m.

“U.S. Tax Reform: International Tax Planning’s Adjustment to Rapid Change” — U.S. corporate tax reform is front and center on the Washington agenda for 2017. As the contours of these reforms become more defined, the developments and discussions – including a possible border adjustment tax – are being followed closely by the global tax community. At the intersection of tax and international trade, non-US companies and investors are assessing potential consequences of the reform for their U.S. investments or more broadly their corporate structures. This international panel will focus on how the likely proposed U.S. tax reforms fit in with global tax trends and developments as well as the potential implications of U.S. tax reform for multinational companies and foreign investors in the U.S. Learn what VAT and GST mean in practice and more broadly, what U.S. domestic tax developments may keep your international client up at night and why, and what actions are already being contemplated or even taken outside of the U.S.

Saturday, 9:00 – 11:30 a.m.

A complete agenda can be found online.

There is no charge for media covering this event. To register, please contact Theresa Melton at 202-662-1516 or Theresa.Melton@americanbar.org.

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