IFA USA New York Region Fall Conference on Tax Reform

Event Location:

EY LLP
5 Times Square
New York, NY, 10036

Program:

• Financing Related Issues and The Base Erosion Provisions
  This panel will discuss proposed limitations on the deductibility of interest and related-party payments, including under the proposed thin cap rules and disproportionate leverage tests included in both bills, the House's proposed excise tax regime, and the Senate's proposed Base Erosion Anti-Abuse Tax and anti-hybrid rules.
• New Dividend Participation Exemption System and the Transition Repatriation Tax
  The Panel will discuss the technical issues surrounding the transition tax with the move to the new territorial based system and resulting participation exemption system for future earnings.
• The New Subpart F Regime
  This panel will compare the HYRA contained in the House bill to the GILTI as contained in the Senate version of the bill. It will also discuss the technical issues surrounding the new GILTI Subpart F regime as well as the FDII provisions. The panel will provide some high-level considerations concerning the impacts on intangible structures.
• Planning for and in the New Era
  The tax reform proposals in Congress, if enacted, will require viewing international structures through a new lens. This panel will cover cross border structuring implications for intangibles, financing, supply chains and transactions.