UC-San Francisco Hosts Conference On U.S. International Tax Rules: Options For Change

UC-San Francisco hosts a conference on Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change today (registration): 

An east coast version of this conference was organized by the American Enterprise Institute and the University of Florida and was held in June 17-18, 2024 in Washington, D.C. More information about that conference can be found here. This west coast version of the conference will focus on the international tax provisions most relevant to technology- and intangibles-based enterprises.

Welcome 

• Mindy Herzfeld (Florida) 
• Heather Field (UC-San Francisco; Google Scholar) 

Session #1: Taxing of CFC Earnings – GILTI and Subpart F

The panelists will explore design issues of Subpart F income and GILTI, their differences, and opportunities for harmonization post TCJA.

• Kara Mungovan (Davis Polk), Subpart F and GILTI Recommendations, 115 Tax Notes Int'l 729 (July 29, 2024) 
• Gretchen Sierra (Deloitte) (commentator)
• Brian Jenn (McDermott) (commentator) 

Session #2: Foreign Tax Credit

The panelists will discuss recommendations for improving the Foreign Tax Credit system including recommended approaches to limitations, basketing, expense allocation, among others.

• Moshe Spinowitz (Skadden) 
  • FTC Proposals, Part I: Creditable Foreign Taxes, 184 Tax Notes Fed. 1443 (Aug. 19, 2024) 
  • FTC Proposals, Part II: TCJA White Paper, 184 Tax Notes Fed. 1631 (Aug. 26, 2024) 
• Julia Ushakova-Stein (Fenwick) (commentator)
• Rachel Kleinberg (Sidley) (commentator) 

Session #3: Sourcing Rules

This panel will discuss some of the pitfalls and difficulties associated with the domestic source of income rules, potential for reexamination of the sourcing rules, and considerations for whether potential reforms could simplify the current system.

• Nita Asher (PwC), Considerations for Reforming The U.S. Source of Income Rules, 115 Tax Notes Int'l 333 (July 15, 2024)
• Gary Sprague (Baker McKenzie) (commentator)
• Chad Hungerford (Deloitte) (commentator)

Session #4: FDII Benefit

The panelists will discuss policy goals for enacting FDII compared to other regimes, whether these goals were met, and areas for potential improvements.

• Pat Brown (PwC), Taxation of Foreign-Derived Intangible Income, 115 Tax Notes Int'l 711 (July 29, 2024) 
• Kyle Pomerleau (AEI) (commentator)
• Becky Lester (Stanford; Google Scholar) (commentator)

Session #5: Transfer Pricing

This session will focus on whether the regulatory arm’s length standard should be incorporated into the statute, whether the special statutory rules applicable to intangible property should be restated or reconsidered in light of developments, whether ancillary transfer pricing rules should be better coordinated with section 482, and whether other changes should be considered in light of

• Rocco Femia (Miller), Considerations for Reforming The U.S. Transfer Pricing Rules, 115 Tax Notes Int'l 171 (July 8, 2024)
• Nate Carden (Skadden) (commentator)
• Rafi Mottahedeh (Shartsis Friese) (commentator)

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