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 - 8:15

REGISTRATION AND CONTINENTAL BREAKFAST

Sponsored by Fenwick & West

8:15 - 8:30 WELCOME
  • Rick Eigenbrode, Managing Director, International Taxes - Applied Materials, TEI Santa Clara Valley Chapter President
  • Annette Nellen, Tax Professor, San Jose State University
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
10:10 - 10:30 BREAK
10:30 - 12:00 BREAKOUT SESSION A
IRS Examination Practices and Strategies

Explanation of the Quality Exam Process that replaces the joint audit planning processes and its significance to LMSB taxpayers. 
 
  • Michael J. Bernard, Tax Counsel
    Microsoft Corporation
  • Patricia Chaback, LMSB-Industry Director for Communications, Technology & Media
    Internal Revenue Service
  • Barbara Leonard, Area Counsel, Communications, Technology & Media
    Internal Revenue Service
  • Thomas Wilson, Senior Managing Director - IRS Services
    PriceWaterhouseCoopers

BREAKOUT SESSION B
Successful Tax Practice in China and India

Tips for ensuring proper tax compliance in these countries, transfer pricing considerations, asset transfers, relevance of Vodaphone decision, and more.

  • Ajay Agarwal, Senior Manager
    KPMG India Center of Excellence
  • Jon Eichelberger, Partner
    Baker & McKenzie
  • Lili Zhang, Managing Director - US Tax Services, Hong Kong
    Deloitte

 


12:00- 1:30

LUNCHEON  & SPEAKER
  • Eric Solomon, Director of National Tax
    Ernst & Young

    Former Assistant Secretary for Tax Policy, U.S. Treasury Dept.
     
1:45 - 3:15

GETTING PROPER RESEARCH CREDIT
A review of the significance of recent research credit rulings and tips for ensuring that high technology companies are effectively capturing, documenting and sustaining the research credit upon federal and state examination

  • Mark Andrus, Partner - Strategic Federal Tax Services
    Grant Thornton
  • Jeffery Jones, Partner-National R&D Practice, West Region Leader
    PriceWaterhouseCoopers
  • Roger Kave, Associate Issue Counsel for R&D Credit
    Internal Revenue Service
3:15 - 3:35 BREAK
Sponsored by Deloitte


3:35 - 4:10

INTERNATIONAL AND MULTISTATE CONCEPTS - SIMILARITIES, DIFFERENCES AND TRAPS
A point and counterpoint on international and multistate principles that are similar yet have key distinctions that missed, can cause problems.  Concepts discussed include permanent establishment, nexus, treatment of mobile employees, and audit approaches of these issues by taxing authorities.

  • Bart Bassett, Tax Partner
    Morgan Lewis
  • Kim Reeder, Tax Partner
    Morgan Lewis

 

4:10 - 5:30 ECONOMIC SUBSTANCE
After years of proposals, health reform brought about codification of the economic substance doctrine.  How does the new rule work and how will it affect tax planning and IRS examinations?
  • Karen Gilbreath Sowell, National Tax Dept.
    Ernst & Young
    Former Deputy Assistant Secretary for Tax Policy, U.S. Treasury Dept.
  • Eric Solomon, Director of National Tax
    Ernst & Young

    Former Assistant Secretary for Tax Policy, U.S. Treasury Dept.