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Permanent Establishment Versus Nexus - Digital Economy Taxation

Venue

This is a virtual event, accessible over the phone. Access instructions will be provided after registration.

Description

With widespread digitization of our economy, traditional models of nexus and permanent establishment are dissolving. Multinational companies may be expected to pay income, gross receipts, or net worth taxes to various jurisdictions. Our panel will evaluate where these developments will go in the future and how companies should plan for them.    

Educational Objectives:

• Understand the fundamental implications of South Dakota v. Wayfair on long-established standards of nexus and physical presence
• Learn how the Wayfair decision has impacted company’s tax planning and bottom line
• Gain insights into parallels between Wayfair and the allocation of taxing rights as part of BEPS 2.0
• Understand the position of U.S. Congress and U.S. Treasury in the OECD negotiations
• Evaluate how an OECD outcome on pillar one might affect different businesses

Who would benefit most from attending this program?

• Corporate tax professionals
• Corporate Tax Attorney/Counsel, Controller/Comptroller, CPA/Accountant, General Counsel

Presenters

Beth Bell
  • Tax Counsel
  • U.S. House of Representatives

Beth Bell serves as Tax Counsel on the Committee on Ways & Means for Chairman Richard Neal, handling corporate, international, and other business tax issues.  Previously, she was Policy Director of the U.S. Senate Committee on Small Business and Entrepreneurship and Tax Counsel in the office of Senator Ben Cardin (D-MD). In that role, she served as the Senator’s principal policy advisor and counsel on taxation, retirement, international trade, small business, and monetary policy. Prior to public service, Beth was an associate at Covington and Burling LLP in the firm’s tax and government affairs practice groups. At Covington, she worked on a broad range of international, corporate, and individual tax advisory and controversy issues, along with legislative work on pension reform, state and federal tax reform, and patent reform. From 2004 to 2006, Beth was a research assistant at the Urban Institute and the Tax Policy Center, where she focused on tax reform and tax policy, budget policy, and asset building for low-income families.  She has a J.D. from Harvard Law School and a B.A. from Wesleyan University.

Liz Chien
  • Vice President of Global Tax and Chief Tax Counsel
  • Ripple Labs

Liz Chien is the VP of Global Tax and Chief Tax Counsel at Ripple Labs, an innovative distributed ledger software company that is enabling the world to move value like it moves information today. Liz is responsible for all aspects of taxation at Ripple Labs. She joined Ripple from General Electric, where she was the Global Tax Director and Senior International Tax Counsel for GE's industrial software business, GE Digital. Prior to GE, she served as a policy advisor at the Organization for Economic Cooperation and Development (OECD), where she worked on international tax reform relating to the digital economy in Action 1 of the OECD BEPS Project. Liz is the former Asia-Pacific Head of Tax for Google and was a Tax Director at Softbank Group International. Prior to Google, she was an attorney with the global law firm of Baker & McKenzie LLP in Palo Alto, California, where she advised technology companies on international tax planning, structuring and transfer pricing. Liz has recently been appointed to the State of California’s Blockchain Technology Working Group, whose mandate is to evaluate the State’s use and regulation of the technology.

Liz received her Bachelors and Masters degrees from Stanford University and her Juris Doctor from the University of California, Hastings College of the Law.

Walt Nagel
  • Chief Tax Officer
  • Gannett

Walt Nagel is the Chief Tax Officer for Gannett overseeing all domestic and international taxes and tax reporting to the SEC.  He is an adjunct professor at the Georgetown University Law Center. Prior to joining Gannett, Walt was a partner with Crowell & Moring and Reed Smith, and has served as Vice President and General Tax Counsel with MCI Communications. He is the author of Leading U.S. Supreme Court State Tax Cases, a Bloomberg Tax book, and the co-author of Sales and Use Taxes: General Principles, a Bloomberg State Tax Portfolio. Walt also co-authored Law Journal Press treatises entitled Mutual Funds: Law and Practice, and State Business Taxes, and has contributed to dozens of published articles.

Robert Stack
  • Managing Director, International Tax
  • Deloitte Tax

Bob Stack is a Managing Director in Deloitte’s Washington National Tax international tax practice where he advises U.S. companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation and Development  (OECD). Until January 2017, he was the Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the US Department of the Treasury where he worked directly with the assistant secretary of tax policy and the international tax counsel in developing and implementing all aspects of U.S international tax policy, including treaties, regulations and legislative proposals.

During his tenure at the Treasury Department, Bob was the US lead on BEPS. He led the US efforts with respect to BEPS issues particular to the financial services industry around interest expense limitations, and in that regard worked closely with Saul Rosen of Citibank. He was also actively engaged in interactions with the financial services industry around both FATCA and the regulations under Section 385.

In addition, Bob was the official representative of the Obama administration for international tax policy and represented the U.S. government at the OECD where he was involved in all aspects of the Base Erosion and Profit Shifting (BEPS) initiative. Prior to joining Treasury, Mr. Stack had over 26 years of experience in international tax matters, representing both corporations and individuals.

Moderator: Stuart Gibson
  • Director, International Tax
  • Bloomberg Tax & Accounting

Stuart Gibson joined Bloomberg Industry Group earlier this year after a 30-year career as a senior litigator in the tax division of the U.S. Department of Justice, where he handled high-profile matters such as the first tax shelter promoter summons cases, “Son of BOSS” tax shelter trials, and successful efforts to enforce “John Doe” summonses against large foreign banks. (If you ask, he will tell you he considers himself the illegitimate uncle of FATCA.) After leaving the government, Stuart wrote the chapter on IRS summonses for the current edition of Saltzman & Book on IRS Practice & Procedure. That gig led, in turn, to his nearly 3-year stint as editor at Tax Analyst where Stuart wrote, edited, blogged, and spoke at conferences in the U.S., Canada, and Europe on developments in international tax law. Immediately before joining Bloomberg Tax, Stuart worked in private practice in the Washington, DC office of Chicago-based Schiff Hardin LLP, where he represented taxpayers before the IRS and in court.

Continuing Education

Credits:
1.2 CPE, 1.0 General COA, 1.0 CLE
Practice Areas:
Practice Area: Taxes
Level:
Basic
Production Date:
01/06/2020