TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Friday, September 23, 2011

Villanova Symposium: Taxation of Offshore Accounts, Executive Compensation

Villanova Logo The Villanova Law Review hosts a symposium today on U.S. Taxation of Offshore Activity, and Regulation of Executive Compensation:

Keynote Speech:  John DiCicco (Deputy Assistant Attorney General (Tax), Department of Justice)

Tax Issues Surrounding Individual Offshore Accounts -- This panel will discuss policy and technical issues facing individuals who have placed assets in offshore accounts. The panel will discuss the civil and criminal penalties that face individuals seeking to hide assets offshore as well as the voluntary settlement initiatives that have been offered to individuals. Specific topics the panel will address include (1) use of John Doe summons and treaties to obtain information from offshore banks; (ii) what constitutes a valid voluntary disclosure; (iii) how to promote compliance among individuals who have taken money offshore; and (iv) the impact of FATCA and OECD rules in preventing the issue of offshore accounts to circumvent US taxation.

  • Keith Fogg (Villanova) (moderator)
  • John McDougal (IRS Office of Chief Counsel)
  • Bryan Skarlatos (Kostelanetz & Fink; Adjunct Professor, NYU Graduate Tax Program)
  • Susan Morse (UC-Hastings)
  • Leandra Lederman (Indiana-Bloomington)

Taxation of US MNC's Offshore Operations -- This panel will discuss the tax policy, economic, and political issues and options surrounding the taxation of US MNC's offshore operations. Specific topics will include (i) the opportunity for income shifting by US MNC's; (ii) the range of policy options for addressing income shifting; (iii) the international competitive tax landscape; and (iv) the pros and cons of a territorial vs. a worldwide system of taxation.

  • Dick Harvey (Villanova) (moderator)
  • Rosanne Altshuler (Rutgers)
  • Ed Kleinbard (USC)
  • Mike Durst (Contributing Author, Tax Notes)
  • Fritz Foley (Harvard Business School)

Luncheon Speech: Lee Sheppard (Contributing Editor, Tax Analysts)

Taxation of Executive Compensation -- This panel will discuss the role of the tax laws in regulating executive compensation. In particular, the panel will discuss the use of the tax system to try to affect both the level and type of compensation paid to executives. Special emphasis will be placed on offshore operations. Specific topics will include (i) the opportunity for income discussing incentive pay and deferred compensation.

  • Joy Sabino Mullane (Villanova) (moderator)
  • Kathryn J. Kennedy (John Marshall)
  • Andrew C.W. Lund (Pace)
  • Gregg Polsky (North Carolina)
  • David I. Walker (Boston University)

Concluding Remarks: Leslie Book (Villanova)

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