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.