International tax enforcement by tax authorities around the globe continues with ever increasing stakes for taxpayers and the governments. The complexity of the law is increasing at a blistering place, amidst growth in “anti-abuse” rules, reporting obligations, information sharing, leaks and whistleblowing, shareholder derivative suits, staggering court decisions, multi-lateral enforcement efforts, and last-but-not-least break-the-bank sized penalties. All of this presents significant challenges for planning, compliance and controversies for corporations, high net worth individuals, and investment entities with international tax issues, and the practitioners who advise those taxpayers. Meanwhile, the U.S. continues its aggressive pursuit of corporate and individual taxpayers it perceives as non-compliant.
Continuing its tradition, the Conference will showcase high-level government officials with hands-on responsibilities in international tax enforcement. Last year we had over 15 senior government officials sharing their insights with the group, and we anticipate having another good government turnout in this, our fifth year.
The ABA Section of Taxation and TEI invite in-house and outside tax professionals (both law firms and accounting firms) to benefit from hearing what is going on in the trenches from the government, corporate taxpayers and tax practitioners, and learn about recent developments, procedures and practices, cases, and what they mean for your practice. This conference presents an incredible opportunity for any practitioner who interfaces with the government on international tax issues.
Preliminary topics include LB&I Campaigns; Competent Authority, BEPS, and CBC; Developments in Transfer Pricing; Criminalization of International Tax Planning; Addressing Whistleblower Risks; and Enforcement and Disclosure Issues Regarding Foreign Assets.
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