2014 High Tech Tax Institute

7:30-8:15 AM

Registration and Refreshments

8:15-8:30 AM

Welcome

• Don Blach (President, TEI Santa Clara Valley Chapter)
• Eli J. Dicker (Executive Director, Tax Executives Institute, Inc.)
• Annette Nellen (MST Program Director, San José State University)

8:30-10:10 AM

International High Technology U.S. Tax Current Developments: Comprehensive review of developments relevant to high tech companies.

• Jim Fuller (Partner, Fenwick & West)

10:10-10:30 AM

Break

10:30 AM-12 PM

BEPS and Typical High Tech International Structures: How are the BEPS action items likely to affect typical high tech structures, including treatment of  intangibles income and proposed country by country reporting? Are countries getting out ahead of the OECD in making changes?

• Holly Carmichael (Partner, BDO)
• Gary Sprague (Partner, Baker & McKenzie)
• Robert B. Stack (Deputy Assistant Secretary for International Tax Affairs - Office of Tax Policy, US Treasury Department)
• Brett Weaver (Partner, KPMG)

12-12:40 PM

Lunch

12:40-1:35 PM

Luncheon Speaker: Bloomberg BNA Article by Joyce Cutler - "U.S., OECD Seek to Smash ‘Cash Box' With Coordinated Effort on Intangibles" - Reproduced with permission from Daily Tax Report 218 DTR G-4 (Nov. 12, 2014). Copyright 2014 by The Bureau of National Affairs, Inc. (800-372-1033)

• Robert B. Stack (Deputy Assistant Secretary for International Tax Affairs - Office of Tax Policy, US Treasury Department)

1:40-3:30 PM

BREAKOUT A

Doing Business in Brazil: Update on tax rules, tax issue resolution, transfer pricing, withholding taxes, and business strategies.

• Leonardo Homsy (Partner, Campos Mello Advogados - Brazil)
• Andy Mattson (Partner, Moss Adams)
• Hugo Amano (Partner, BDO Brazil)

BREAKOUT B

IRS Examination Developments for High Tech Firms: A review of best practices, the new IDR process, effective tax administration and the relevance of possible tax reform.

• Patricia C. Chaback (Executive Director, EY; Former Industry Director for CTM, IRS)
• Cheryl P. Claybough (LB&I - Industry Director for Communications -Technology & Media, IRS) Invited
• Larry R. Langdon (Partner, Mayer Brown LLP; Former Commissioner LMSB, IRS)
• Tony Shabazz (LB&I - Territory Manager for Communications - Technology & Media, IRS) Invited

3:30-3:45 PM

Break

3:45-5:15 PM

BREAKOUT C

FATCA and Its Relevance to High Tech Companies: The Foreign Account Tax Compliance Act (FATCA) is generally viewed as relevant to foreign financial institutions as well as individuals with foreign financial assets to report. Yet, the reach of FATCA can be broader with even high tech companies potentially required to deal with its reporting and withholding requirements.

• Pamela Endreny (Partner, Skadden)
• Peter Larsen (Senior Manager, Deloitte)
• Dharmish Pandya (Partner, DLA Piper)

BREAKOUT D

Virtual Currency — Virtual Tax Effects Too?: An examination of the types and uses of virtual currencies and the international, federal and state tax considerations in using it.

• Rob Massey (Partner, Deloitte)
• Annette Nellen (Professor and MST Program Director, San José State University)
• Eric Ryan (Partner, DLA Piper; Adjunct Instructor, San José State University)

7:30-8 AM

Registration and Refreshments

8-9:15 AM

Accounting for Income Taxes: A review of new developments relevant to high tech firms, including PCAOB activities and how tax reform effects the provision.

• Amy Chan (Director, KPMG)
• Irine Dibowitz (Executive Director, EY)
• Patrice Mano (Partner, Deloitte)
• Jesus Ochoa (Tax Director, PwC)

9:15-10:15 AM

BREAKOUT E

Surviving Federal and California Audits of the Research Tax Credit: New approaches and strategies for examining the credit, recordkeeping considerations, and more.

• Carolyn Driscoll (Senior Manager, Moss Adams)
• William Boulet (Director, Deloitte)
• John Scacco (Partner, PwC) 

BREAKOUT F

European VAT Developments: Current developments and issues of VAT compliance, planning and controversy for high tech firms.

• Sandy Nicolson (Principal, KPMG)
• Jan Snel (Partner, Baker & McKenzie)

10:15-10:30 AM

Break

10:30 AM-12 PM

BREAKOUT G

State Tax Incentives — Including California!: Most states have fairly generous incentives for manufacturing, R&D, hiring and more. But, there tend to be numerous restrictions on how and when to claim them. California has new incentives in place with significant accountability measures. This program will review key incentives for high tech firms and tips for claiming them.

• Robyn Davis (Senior Manager, Moss Adams)
• Scot Grierson (Partner, Grant Thornton)
• Brian D. Pedersen (Managing Director, Alvarez & Marsal Tax)

BREAKOUT H

M&A Developments and Internal Restructurings: Domestic M&A and spin-off developments and transactions; cross-border transactions (including inversions), effect of CFC/PFIC rules; S corporations and other passthrough acquisitions, state tax planning.

• Gabe Gartner (Principal, PwC)
• Ivan Humphreys (Partner, Wilson Sonsini)
• David Hering (National Tax M&A Partner, KPMG)
• Mark Jewett (Director - M&A Tax, Amazon.com)

12-12:40 PM

Lunch

12:40-1:25 PM

Luncheon Speaker

Silicon Valley Tax Perspectives - 
Past, Present and Future

• Stephen P. Sedler (Senior Vice President of Tax and International Trade Administration, Seagate Technology

1:30-2:45 PM

The Digital Economy and New Ways Countries Want to Tax It: The OECD and some countries (including the U.S.) have suggested new approaches for taxing the digital economy. This panel will explore the BEPS report, congressional tax reform proposals, and those of a few other countries and explain what it means for taxing international income. Federal tax issues and possible IRS guidance, such as on cloud computing, will also be covered.

• Rod Donnelly (Partner, Morgan, Lewis & Bockius)
• Sadler Nelson (Partner, EY)
• David Forst (Partner, Fenwick & West)
• James O’Neal (Tax Principal, AMMC Law)

2:45-3 PM

Break

3-4:15 PM

Executive Compensation: Current trends and issues involving Section 162(m), fringe benefits, stock options, global mobility, multistate issues, and health care.

• Handy Hevener (Partner, Morgan, Lewis & Bockius)
• Jason Russell (Tax Director, Deloitte)

4:15-5:30 PM

Federal Domestic and State Tax Updates: Recent developments in accounting methods, nexus, sourcing, digital goods, recent legislative activities, as well as the outlook for 2015.

• James Besio (Executive Director, EY)
• Don Corbett (Tax Partner, Grant Thornton)

8-8:30 AM

Registration and Refreshments

8:20-8:30 AM

Welcome

• Annette Nellen (Professor and Director of the High Technology Tax Institute, San José State University)

8:30-10 AM

Understanding the Federal and California Research Tax Credits

• Debbie Heard (Sr. Manager, KPMG)
• Dan Mennel (Managing Director, KPMG)

10-10:15 AM

Break

10:15-11:45 AM

Inversions — Structuring and Basic Tax Rules

• Brandon Hayes (Partner, EY)

11:45 AM-12:30 PM

Lunch

12:30-1:45 PM

What’s a VAT?

• Shoab Malak (Director - Global VAT Services, Deloitte)

1:45-2 PM

Break

2-3:15 PM

BEPS — Basics, Relevance, Underlying Tax Principles and Policies

• Taylor Reid (Partner, Baker & McKenzie)
• Ivan A. Morales (Partner, Baker & McKenzie)

3:15-4:30 PM

Property Transactions Basics as a Foundation for Understanding Virtual Currency and Other E-Commerce Matters

• Annette Nellen (Professor and Director of the SJSU MST Program, San José State University)