Introduction

 

Fees and Registration

 

 

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

 

High Tech Tax Institute Academy
October 23, 2015

SJSU Campus

See agenda below

 

TEI-SJSU High Tech Tax Institute
November 9-10, 2015

Crown Plaza Cabana
Palo Alto, CA

Google map

REGISTRATION FOR BOTH EVENTS IS OPEN - Click here

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Monday November 9, 2015

Time

Topic

Presenters

7:30 – 8:15

Registration & refreshments

 

8:15 – 8:30

Welcome

 

Neil J. Young, President – TEI Santa Clara Valley Chapter

Eli 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

Practical Consequences of BEPS

  A review of the BEPS Action Items and key issues in them for high tech companies. How country-by-country reporting is addressed in selected countries and the transfer pricing relevance.

 

 

Larissa Neumann, Partner – Fenwick & West LLP [bio]

Feargal O'Rourke, Partner – PwC [Ireland]

Brett Weaver, Partner - KPMG

Shanwu Yuan, International Tax Director – Baker & McKenzie Consulting LLC [China]

 

 

Noon – 12:40

Lunch

 

12:40 – 1:35

Luncheon speaker

TBA

1:40 – 3:30

European Union Hot Topics

  What’s new and hot in the EU? A look at patent or innovation boxes, the UK diverted profits tax, state aid issues, VAT and digital services, reaction to the OECD BEPS activities, and more.

 

James Anderson, Partner Skadden, United Kingdom

Mark O’Sullivan, Partner – Matheson

Paul Rutherford, Partner - DLA Piper, United Kingdom

 

3:30 – 3:45

Break

 

3:45 – 5:15

BREAKOUT A

Subpart F

 Developments and issues regarding subpart F including substantial contribution and branch rule issues.

BREAKOUT B

Cloud Activities and Issues under Sections 41 and 199

  How to address questions that can arise for the research tax credit and manufacturing deduction by new economy transactions such as variations on cloud computing including SaaS.

 

Fred Chilton, Managing Director - KPMG [bio]

Rod Donnelly, Partner – Morgan Lewis

Stewart Lipeles, Partner - Baker & McKenzie LLP

 

 

 

Kevin Dangers, Partner - EY

Rob Kovacev, Partner - Steptoe & Johnson, Washington, DC; former Senior Litigation Counsel, Dept. of Justice [bio]

Dan Mennel, Partner – Grant Thornton

Tuesday November 10, 2015

Time Slot

Topic

Presenters

7:30 – 8:00

Registration & coffee

 

8:00 – 9:00

Accounting for Income Taxes

 Update and guidance on issues involving stock options and other equity compensation, employee mobility and tax reform.

Tom Dong, Partner – Deloitte

Louis Gomes, Partner – BDO

Dean Kamahele, Principal – KPMG

9:00 – 10:15

 

 

State Tax Reform

  Why are states honing in on tax haven and transfer pricing matters? What reforms are underway by the states and MTC?  Tax accounting issues will also be addressed.

Annette Nellen, Professor – SJSU MST Program [bio]

Brian Pederson, Managing Director – Alvarez & Marsal Taxand

Rob Weyman, Senior Associate - ReedSmith [bio]

10:15 – 10:30

Break

 

10:30 - noon

Repatriation Strategies versus Reinvestment Overseas

  Discussion will include administrative developments, planning ideas such as sale of IP and holding companies, APB 23 considerations and more.

 

Nick DeNovio, Partner – Latham and Watkins

Jimmy Man, Partner- Deloitte

Ty Kanaaneh, Partner - PwC

12  – 12:40

Lunch

 

12:40 - 1:25

Luncheon Speaker

Heather C. Maloy, Tax Controversy Leader, EY; former IRS Commissioner for Large Business & International (LB&I) Division

1:30 – 3:00

 

 

IRS Developments and Examination Strategies

  A update on the LB&I organizational structure, the Quality Exam Process, international procedures and field coordination, competent authority, mediation practices, and use of third party law firms in the examination process.

Pat Chaback, Executive Director - EY [bio]

Cheryl Claybough, Industry Diretor, CTM - IRS

Eli Dicker; Executive Director – Tax Executives Institute, Inc.

Larry Langdon, Partner – Mayer Brown

Andy Mattson, Partner – Moss Adams [bio]

Tony Shabazz, Territory Manager - IRS

3:00 – 3:15

Break

 

3:00 – 4:30

What’s Hot and What’s New in M&A

  Cross-border M&A (including inversions), PE Firm buyouts of technology companies, spin-offs, NOL planning, IPO structuring, BEPS, and related topics.”

 

Gabe Gartner, Partner - PwC

Nate Giesselman, Partner – Skadden [bio]

Ivan Humphreys, Partner – Wilson Sonsini

Laynie Pavio, Partner – EY

4:30 – 5:30

Domestic and Multistate Update

  Developments of relevance to high tech companies including internal use software regulations, other research credit developments, California update and key guidance and areas to watch at the state and multistate level including sourcing and apportionment.

 

Don Corbett, Partner – Grant Thornton (Federal)

John Clausen, SALT Director – Moss Adams (state)

 

 

High Tech Tax Institute Academy
Friday, October 23, 2015
SJSU Campus

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

Accounting for Income Tax Law Changes – Relevant GAAP Guidance

Louis Gomes, Partner - BDO

10:00 – 10:15 

Break

10:15 – 11:45

Basics of Section 199 for High Tech Companies

Michael K. Palmer, Director - PwC [bio]

Nikki Zar, Director - PwC [bio]

11:45 – 12:30

Lunch (provided)

12:30 – 1:45

The Process of an IRS Examination of a High Tech Company

Emily M. Lam, Partner – Skadden [bio]

1:45 – 2:00 

Break

2:00 – 3:15 

Subpart F

Anthony D. Cipriano, Associate – Morgan Lewis
Neal Gordon, Of Counsel – Morgan Lewis

3:15 – 4:30 

Nature and Rationale of State Tax Reform

Toni Lewis, Director - Deloitte

 

Conference Sponsors

 

                                                  TEI Logo

Santa Clara Valley Chapter

 

SJSU Logo

LUCAS COLLEGE AND GRADUATE SCHOOL OF BUSINESS

 


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.