Introduction

Topics

Speakers

Sponsors

Schedule

Fees

Registration

Hotel Reservations

CPE Form

Advisory Board

26th

HIGH TECHNOLOGY TAX INSTITUTE

SCHEDULE

Monday, November 8 | Tuesday, November 9

7:30 - 8:00	REGISTRATION AND CONTINENTAL BREAKFAST
8:00 - 9:45	ACCOUNTING FOR INCOME TAXES AND ITS CHALLENGES Topics include buy-ins, valuation allowances, §162(m), foreign exchange/translation, §988, 986 and 987, functional currency, FIN 48 considerations, FAS 52, hedging and more. Scott Jaconetty, Partner BDO Seidman Glen Kohl, Senior Vice President-Tax and Treasury Electronic Arts Tony Rebelo, Partner Ernst & Young Jeff Sokol, Partner; Faculty, SJSU MST Program Deloitte Rusty Thomas, Tax Partner KPMG
9:45 - 10:00	BREAK Sponsored by Thomson Reuters
10:00-11:45	UNCERTAIN TAX POSITIONS - TAX RETURNS AND FINANCIAL STATEMENTS The new IRS program explained along with tips for effective compliance in line with FIN 48 requirements. Explanation of future work by the IRS in this area and how the new program will affect IRS examinations. Panel will also address the IRC §7525 privilege, work product doctrine and changes based on the Textron decision. Patricia Chaback, LMSB-Industry Director for Communications, Technology & Media Internal Revenue Service Larry R. Langdon, Partner Mayer Brown LLP Former Commissioner LMSB, IRS Heather Maloy, Commissioner LMSB, Internal Revenue Service Michael Reichert, Global Managing Tax Partner Deloitte Neil D. Traubenberg, Past International President Tax Executives Institute, Inc.
11:45 - 1:15	LUNCH AND SPEAKER Heather Maloy, Commissioner LMSB, Internal Revenue Service
1:30 - 3:00	BREAKOUT SESSION C Cross Border Issues Transfers of intangibles, cost sharing, future 482 guidance, and legislative proposals concerning intangibles. David Bowen, Principal Grant Thornton Steven A. Musher, Associate Chief Counsel (International) Internal Revenue Service Ron Schrotenboer, Partner Fenwick & West BREAKOUT SESSION D Cloud Computing Primer A technological overview along with an explanation of the various international, federal, multistate and local tax issues that come into play and some of the limited guidance that exists. Rocky Cummings, Partner - National Leader Multistate Tax Services BDO Seidman Paul Sallomi, U.S. Tax Industry Leader - Technology Deloitte Brett A. Weaver, Partner KPMG
3:00 - 3:20	BREAK Sponsored by Ernst & Young
3:20 - 4:30	M&A HOT TOPICS A review of recent developments relevant to high tech companies, contingent value rights, compensation techniques, GAAP and IFRS implications, IP restructuring, and FAS 141R implications. Danni Dunn, Partner; Faculty, SJSU MST Program Ernst & Young Ivan Humphreys, Partner Wilson Sonsini Goodrich & Rosati Kirt Switzer, Partner Latham
4:30 - 5:30	FEDERAL DOMESTIC AND STATE TAX UPDATES Recent developments in R&D, accounting methods, nexus, digital goods, recent legislative activities, as well as the outlook for 2011. Tony Fuller, Managing Director Alvarez & Marsal Taxand Annette Nellen, Professor San Jose State University