1. business and industrial
2. company
3. merger and acquisition

TAX CONFERENCE
Wednesday, May 13th to Saturday, May 16th at the Ritz-Carlton, Dove Mountain
CONFERENCE CO-CHAIRS
KAREN HALBY
Senior Vice President, Head of Global Tax
Sony Corporation of America
GARY HICKMAN
Senior Vice President, Tax & Risk Management
Oldcastle
PROGRAM
Wednesday, May 13th
7:00 PM to 9:00 PM
Thursday, May 14th
WELCOME RECEPTION
7:30 AM
BREAKFAST AVAILABLE
8:00 AM to 9:30 AM
OFII YEAR IN REVIEW: 2015 ADVOCACY PRIORITIES
OFII will provide an update on our legislative priorities and initiatives at both the state and
federal levels.
9:30 AM to 11:00 AM
TAX LEGISLATION: OUTLOOK FOR REFORM
The current legislative outlook includes talk of potential tax reform from both sides of the aisle. Will it be real this time? What are the potential outcomes? Who will be the winners and losers?
Regulatory actions could include anti-inversion regulations pursuant to Notice 2014-52, and
regulations on valuing IP. In addition, this session will discuss the future of interest deductibility in
light of OECD actions, and possible U.S. responses.
SPEAKERS
JASON BAZAR
Mayer Brown
BILL DODWELL
Deloitte
WARREN PAYNE
Mayer Brown
JON TRAUB
Deloitte
11:15 AM to 12:45 PM
BREAKOUT SESSIONS
Participants will attend their first of two selected breakout sessions for the day.
TOPICS
1) FINANCING STRUCTURES FOR A CHANGING TAX LANDSCAPE
This session will explore the future tax landscape impacting global capital structures. We will
discuss the impact of BEPS Actions 2 (hybrids), 4 (debt), and 6 (treaties) on current intercompany
financing structures, and what alternatives may be viable in the future.
SPEAKERS
JON GOLDBLATT
Deloitte
SCOTT STEWART
Mayer Brown
BOB STRICOF
Deloitte
2) TRENDS & TRANSACTIONS: IP MIGRATION & COST SHARING
This session will discuss in depth cutting-edge issues in IP ownership and IP migration including:
defining substance and IP ownership when control of IP is dispersed globally and managed
virtually; observations on the economics of sophisticated licensing models such as fixed or hybrid
fixed/contingent royalties, options, contingent services, and profit splits; advances in IP partner
ships (e.g., special allocations of R&D, tracking preferred, curative allocations as an alternative to
remedial allocations); and corporate freeze structures using 20-year recovery and/or dividend
offsets. We will also discuss the practical challenges of operating under these structures after
they are implemented.
LEW GREENWALD
SPEAKERS
Mayer Brown
DAN MARKIEWICZ
Deloitte
KEITH REAMS
Deloitte
SPEAKERS
3) MANAGING U.S. CASH TAXES
This session will focus on current opportunities to reduce cash taxes by deferring revenue and
accelerating expenses and cost recovery. We will discuss planning opportunities with tangible
property as well as the accounting methods that our inbound companies have successfully
implemented.
TOM DRISCOLL
Deloitte
ED OSTERBERG
Mayer Brown
TOM REYER
Deloitte
12:45 PM
LUNCH IS SERVED
1:00 PM to 2:30 PM
BEST PRACTICE DISCUSSION
This session, lead by OFII tax leadership, will provide a closed-door forum for participants to
share experiences and discuss issues of common concern.
2:45 PM to 4:15 PM
BREAKOUT SESSIONS
Participants will attend their second selected breakout session of the day.
4:15 PM
SESSIONS CONCLUDE
7:00 PM
DINNER
Friday, May 15th
7:30 AM
BREAKFAST AVAILABLE
8:00 AM to 9:30 AM
LATEST TRENDS IN TAX CONTROVERSY
Current IRS enforcement is being shaped by external forces (e.g., BEPS-like arguments for risk
and control, a novel transfer pricing technique from Germany) and internal changes (e.g., LB&I
changes, AJAC). How do these changes affect your transfer pricing? Valuation of intangible assets?
Handling requests for extraterritorial information? APAs? IRS audits and appeals strategy? Penalty
defenses? Reserves? This session will identify the practical implications of these trends for your
organization.
SPEAKERS
CABELL CHINNIS
Mayer Brown
KERWIN CHUNG
Deloitte
JASON OSBORN
Mayer Brown
9:45 AM to 11:15 AM
BREAKOUT SESSIONS
Participants will attend their first of two selected breakout sessions for the day.
TOPICS
1) BUSINESS MODELS OF THE FUTURE
This session will consider current best practices and emerging issues on supply chain planning
regarding U.S. manufacturing and U.S. distribution. We will discuss the tax and business issues
associated with U.S. manufacturing under contract and toll arrangements, the future of LRDs and other business fragmentation structures, and (if relevant) the impact of home country actions
such as the UK diverted profits tax on supply chains. The session will also address emerging
trends regarding IP ownership and risk allocation.
SPEAKERS
SPEAKERS
JIM BARRY
Mayer Brown
GRETCHEN SIERRA
Deloitte
MICHAEL STEINSALTZ
Deloitte
2) THE IMPORTANCE OF WELL-DRAFTED INTERCOMPANY AGREEMENTS IN TAX PLANNING
Intercompany agreements generally form the basis of a company’s economic, functional, legal,
and tax positions. IRS and worldwide tax authorities routinely request copies of intercompany
agreements during examinations. A poorly-drafted intercompany agreement may deprive a
taxpayer of the benefits of good tax planning and generate unnecessary tax controversies. This
session will present the best practices in drafting intercompany agreements using real examples
(intercompany notes, services agreements, employment contracts, etc.) to demonstrate how to
bolster a taxpayer’s tax positions. The audience will learn practical tips and a basic approach to
drafting intercompany agreements that will be beneficial, defensible, and sufficiently flexible and
enduring to the company.
DAN DUMEZICH
Deloitte
ERIN GLADNEY
Mayer Brown
SHAWN O’BRIEN
Mayer Brown
SPEAKERS
3) ANATOMY OF A TRANSFER PRICING CASE
For most taxpayers, defending your company’s transfer pricing in audit and being ready for
appeals (if necessary) is the single largest tax controversy concern. Building on the tax
controversy trends session, this session will provide practical help with anticipating this challenge
by reviewing the typical evidence that must be developed, showing why such evidence is
important, and discussing where in the corporate structure such evidence may be found. In
addition, this presentation will discuss how to build a successful position within the evolving
procedures in LB&I and IRS Appeals, including the work that must be done properly in audit in
order to be ready for IRS appeals under the new AJAC rules.
PAUL DISANGRO
Mayer Brown
MIKE EMERSON
Mayer Brown
ELENA
KHRIPOUNOVA
Mayer Brown
11:30 AM to 1:00 PM
BREAKOUT SESSIONS
Participants will attend their second selected breakout session of the day.
1:30 PM to 5:00 PM
AFTERNOON ACTIVITIES
7:00 PM
Saturday, May 16th
DINNER
8:00 AM
BREAKFAST AVAILABLE
CONFERENCE CONCLUDES
ROB PLUNKETT
Deloitte