Webinar September 29-October 2, 2020

Virtual 2020 Fall Tax Meeting

Sam Kaywood, Danny Reach, Heather Ripley, and Richard Slowinski will speak at this conference hosted by the American Bar Association (ABA) Tax Section.

Sam Kaywood will be a panelist for “Final Section 267A Regulations: A Deep Dive.” The panelists will discuss the final anti-hybrid regulations under Section 267A, with a focus on the significant changes made from the proposed regulations.

Danny Reach will serve as a moderator for “Section 1061 – Clearing the Three-Year Hurdle.” Practitioners finally have the much-awaited proposed regulations under Section 1061, one of the more inscrutable provisions included in the TCJA. This esteemed group of panelists will discuss the recently released proposed regulations, initial taxpayer and practitioner reactions, and potential short-term and long-term impacts (pun intended) on carried interest structuring and planning going forward.

Heather Ripley will be a panelist for “Tax Residence and Nexus in the Time of the Plague.” Foreign individuals have always had to closely monitor application of the U.S. tax residency rules given the significant tax consequences of being a resident alien, including taxation of worldwide income and extensive reporting requirements. The COVID-19 pandemic has complicated this calculus, due to travel disruptions, quarantines, border closures, and infection risk. Workers trapped and working remotely in the United States may surprisingly find their earnings subject to tax, and these individuals’ activities may unexpectedly create tax nexus or permanent establishment risk and expose their employers to U.S. tax liability. This panel will discuss the limited relief provided by the IRS to address these challenges and practical planning considerations to manage (if not avoid) these risks.

Richard Slowinski will be a panelist for “Transfer Pricing for a Pandemic Economy.” In this session, panelists will survey the pandemic’s effects and business responses from a transfer pricing perspective, exploring the implications of business model changes, the relationship of these changes to intercompany contracts and arrangements, and the pandemic’s effects on access to external financing and on intercompany funding. Panelists will also analyze how losses and risks should be evaluated and allocated in a pandemic economy and the unique implications for taxpayers operating under APAs or rulings. Throughout, the panelists will identify whether and how existing IRS and OECD guidance apply to the current challenges and where supplemental guidance could enhance tax certainty.

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Media Contacts
Alex Wolfe
Communications Director

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