Introduction

 

Fees and Registration

 

Hotel Reservation Information

 

Continuing Education

 

Sponsors

 

Advisory Board

The Contemporary Tax Journal

SJSU MST Program and Course Schedule

History
(includes agendas and materials from past High Tech Tax Institutes, Tax Policy Conferences, and Small Business Tax Institutes)

 

Annette Nellen, Director

 

30th Annual TEI-SJSU
High Tech Tax Institute

 

November 10-11, 2014

Crown Plaza Cabana
Palo Alto, CA

Google map

High Tech Tax Institute Academy
October 17, 2014

Sunnyvale (see schedule at bottom of page)

 

Registration open - click here.

 

Agendas (pdf)



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Monday November 10, 2014

Time

Topic

Presenters

7:30 – 8:15

Registration & refreshments

 

8:15 – 8:30

Welcome

 

Don Blach.; President – TEI Santa Clara Valley Chapter

Eli J. Dicker, Executive Director - Tax Executives Institute, Inc.

Annette Nellen, MST Program Director - SJSU

8:30 – 10:10

International High Technology U.S. Tax Current Developments

 Comprehensive review of developments relevant to high tech companies.

 

Jim Fuller, Partner - Fenwick & West LLP

 

10:10 – 10:30

Break

 

10:30 - noon

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, LLP [bio]

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

Brett Weaver, Partner - KPMG [bio]

Noon – 12:40

Lunch

 

12:40 – 1:35

Luncheon speaker

 

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

1:40 – 3:30

BREAKOUT A

Doing Business in Brazil

  Update on tax rules, tax issue resolution, transfer pricing, withholding taxes, and business strategies.

 

 

 

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.

 

Leonardo Homsy, Partner - Campos Mello Advogados - Brazil

Andy Mattson, Partner – Moss Adams LLP

Hugo Amano, Partner - BDO Brazil [bio]

 

Patricia C. Chaback, Executive Director – EY; former Industry Director for CTM, IRS

Cheryl P. Claybough, LB&I - Industry Director for Communications, Technology & Media – Internal Revenue Service -invited

Larry R. Langdon, Partner - Mayer Brown LLP; former Commissioner LMSB, IRS

Tony Shabazz, LB&I - Territory Manager for Communications, Technology & Media – Internal Revenue Service - invited

 

3:30 – 3:45

Break

 

3:45 – 5:15

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.

 

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.

 

Pamela Endreny, Partner - Skadden

Peter Larsen, Senior Manager - Deloitte

Dharmish Pandya, Partner – DLA Piper

 

 

Rob Massey, Partner – Deloitte

Annette Nellen, Professor and MST Program Director - SJSU [bio]

Eric Ryan, Partner – DLA Piper; Adjunct Instructor - SJSU

 

Tuesday November 11

Time

Topic

Presenters

7:30 – 8:00

Registration & coffee

 

8:00 – 9:15

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 LLP

Irine Dibowitz, Executive Director - EY

Kelly Gaffaney, Partner - Deloitte

Ty Kanaaneh, Partner - PwC

9:15 – 10:15

 

 

BREAKOUT E

Surviving Federal and California Audits of the Research Tax Credit

  New approaches and strategies for examining the credit, recordkeeping considerations, and more.

 

BREAKOUT F

European VAT Developments

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

 

Carolyn Driscoll, Senior Manager – Moss Adams LLP

William Boulet, Director - Deloitte

John Scacco, Partner - PwC [bio]

 

Sandy Nicolson, Principal – KPMG LLP

Bert Laman, Global Leader Indirect Tax Group – Mazars (Moss Adams)

 

10:15 – 10:30

Break

 

 

10:30 - noon

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.

 

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.

Robyn Davis, Senior Manager – Moss Adams LLP

Scot Grierson, Partner – Grant Thornton

Brian D. Pedersen, Managing Director - Alvarez & Marsal Taxand, LLC

 

 

Gabe Gartner, Principal - PwC [bio]

Ivan Humphreys, Partner - Wilson Sonsini

David Hering, National Tax M&A Partner – KPMG LLP

Mark Jewett, Director – M&A Tax – Amazon.com
12 - 12:40 Lunch
12:40 - 1:25 Luncheon Speaker

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

 Silicon Valley Tax Perspectives -
Past, Present and Future
 

1:30 – 2:45

 

 

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, LLP

James O’Neal, Tax Principal - AMMC Law

Kent Wisner, Adjunct Instructor - UC Berkeley School of Law

2:45 - 3

Break

 

3:00 – 4:15

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  [bio]

Jason Russell, Tax Director - Deloitte

4:15 – 5:30

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

 

High Tech Tax Institute Academy
Friday, October 17, 2014
Location -
Plug and Play, 440 N. Wolfe Rd., Sunnyvale, CA  94085

Google map.

Agenda 

Time

Topic

Presenters

8:00 – 8:30 am

Registration and coffee/snacks

8:20 – 8:30

Welcome

Annette Nellen, Professor and Director of the High Technology Tax Institute – San Jose State University

8:30 – 10:00

Understanding the Federal and California Research Tax Credits

 

Debbie Heard, Sr. Manager, KPMG LLP [bio]

Dan Mennel, Managing Director, KPMG LLP [bio]

10:00 – 10:15 

Break

10:15 – 11:45

Inversions – Structuring and Basic Tax Rules

Laynie Pavio, Principal - EY

11:45 – 12:30

Lunch (provided)

12:30 – 1:45

What’s a VAT?

Shoab Malak, Director, Global VAT Services - Deloitte  [bio]

1:45 – 2:00 

Break

2:00 – 3:15 

BEPS – Basics, Relevance, Underlying Tax Principles and Policies

Taylor Reid, Partner – Baker & McKenzie LLP

Ivan A. Morales, Partner – Baker & McKenzie LLP

3:15 – 4:30 

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 Jose State University [bio]

 

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Conference Sponsors

 

                                                  TEI Logo

Santa Clara Valley Chapter

 

SJSU Logo

LUCAS COLLEGE AND GRADUATE SCHOOL OF BUSINESS

 

 

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Questions?
Contact Tax Institute Director Annette Nellen at SJSU -

annette.nellen@sjsu.edu

Tax Identification Number for the SJSU High Tax Institute is 94-6017638.