Thursday, December 10, 2015

Kilpatrick Townsend’s Annual Domestic & International Tax Discussion for Businesses and Advisors
Kilpatrick Townsend & Stockton LLP
1100 Peachtree Street NE, Suite 2800, Atlanta, Georgia 30309

8:00 a.m.-8:10 a.m.
Introduction
Chuck Hodges

8:10 a.m.-9:10 a.m.
2015 M&A Update – Use of LLCs and Partnerships in Consolidated Groups
Lynn Fowler and Heather Preston
This panel will explore potential uses for including LLCs and partnerships in a consolidated group structure, including potential tax planning opportunities using partnership structures.

9:10 a.m.-10:10 a.m.
Chuck Hodges and Vanessa Tollis
This panel includes a tax litigator and international tax attorney who will discuss current domestic and international issues that arise in IRS audits. The presentation will emphasize how decisions made during the transactional stages and return preparation process impact the outcome of the examination, especially for those issues involving experts, such as with transfer pricing. The panel will address current issues, including IRS transfer pricing roadmap, informal cross border IP transfers, tax treaty positions, foreign tax credits, withholding taxes, the continued emphasis of the IRS on information disclosure, including Foreign Bank Accounting Reporting (FBAR) rules and FATCA, and the impact in the U.S. of the OECD’s BEPS initiative.

10:10 a.m.-10:20 a.m.
Break

10:20 a.m.-11:20 a.m.
Recent Tax Developments and What to Watch for in 2016 
Jamie Brown, Antoinette Ellison, Susan Rathje and Vanessa Tollis
This panel will review a number of important new developments in Employment Tax; International Tax; State and Local Tax; and Partnership Audits. We will also provide perspective on what to expect in these areas in the year ahead.