Tax Executives Institute

Tax Executives Institute

International Tax Seminar

April 26th, 2012

Proposed Session Topics & Timeline (Presentation Time = 350 min / 7.0 CPE credit hours)

9:00 - 10:15 am Session I - International Legislative Update (75 min)

Review of various international tax reform proposals and considerations, including:

·  Overview of US international tax system

·  Review of various territorial regime proposals, including Obama administration proposals; Chairman Camp's proposals; Senator Enzi proposals; etc.

·  Other recent legislative developments

10:15 - 10:35 am Break

10:35 - 12:05 pm Session II - Regulatory Developments (90 min)

Review of recently issued regulations and other technical authority, including:

·  FTC Splitter and Technical Taypayer regulations under Section 909 and 901

·  Interest expense apportionment regulations under Section 861

·  Contract manufacturing regulations

·  Other technical developments

12:05 - 1:05 pm Lunch

1:05 - 2:05 pm Session III - Transfer Pricing Update (60 min)

General update on transfer pricing developments, including:

·  Transfer pricing in troubled economies and industries

·  Recent OECD developments

·  Cost sharing regulations

2:05- 2:50 pm Session IV - International Reporting & Accounting Update (I) (45 min)

Overview of foreign affiliate reporting rules and requirements:

·  E&P and information reporting requirements

·  Accounting method issues / considerations

·  Translation and foreign currency considerations

·  FATCA regulations

2:50 - 3:10 pm Break

3:10 - 4:30 pm Session V - International Reporting & Accounting Update (II) (80 min)

General update on international income tax accounting and foreign tax developments

·  Hot topics in tax accounting for foreign operations

·  US GAAP Accounting for Mexican Affiliates

·  Mexican tax developments

Confirmed Speakers

Session I: Panel

Scott Hesse - Partner, International Tax Services (Detroit)

Jeff Brown - Partner, International Tax Services (Detroit)

Alan Fischl - Principal, International Tax Services (Washington National Tax Services)

Rebecca Rosenberg - Principal, International Tax Services (Washington National Tax Services)

Session II: Panel

Scott Hesse - Partner, International Tax Services (Detroit)

Jeff Brown - Partner, International Tax Services (Detroit)

Alan Fischl - Principal, International Tax Services (Washington National Tax Services)

Rebecca Rosenberg - Principal, International Tax Services (Washington National Tax Services)

Session III: Bill Hahn - Principal, Transfer Pricing

Session IV: David Chen - Director, Quantitative Solutions

Session V: Doug Berg - Managing Director, International Tax & Tax Accounting Services

Fausto Cantu - Partner, Tax & Legal Services & Tax Accounting Services Leader (PwC-Mexico)

Blas Montemayor - Director, International Tax Services (Mexico Tax Desk - New York)