DAY ONE AGENDA

Welcome & Opening Remarks
8:45 – 9:00 AM

Corporate Tax Update 
9:00 – 10:00 AM
• OBBBA, CAMT, and corporate tax legislative developments affecting multinational businesses
• OECD Pillar Two, GloBE, and global minimum tax implementation updates
• GILTI/NCTI, foreign tax credit, and international tax developments impacting corporate structures and planning
• Practical implications for effective tax rate (ETR), forecasting, and cash tax planning decisions
• Tariff, trade, and cross-border tax developments affecting multinational operations and reporting  

Break
10:00 – 10:05 AM

Update on Transfer Pricing 
10:05 – 11:05 AM
• Recent OECD, regulatory, and economic developments affecting transfer pricing strategies
• Transfer pricing implications of tariffs, supply chain changes, and cross-border operations
• DEMPE functions, intangible property considerations, and controversy risk management
• Documentation best practices, audit readiness, and IRS compliance considerations
• Transfer pricing planning considerations involving customs, benchmarking, and operational restructuring 

Break
11:05 – 11:10 AM

Audit Readiness, Documentation & Risk Management  
11:10 AM – 12:10 PM
• IRS audit readiness strategies and practical approaches for managing examinations
• Documentation best practices for supporting tax positions, credits, and compliance filings
• AI-driven IRS enforcement trends, audit triggers, and automated matching initiatives
• Managing uncertain tax positions (UTPs) and areas of elevated tax risk
• Practical strategies for handling IDRs, statute extensions, Appeals, and audit resolution processes

Lunch
12:10 – 12:55 PM

Tax Credits & Incentives
12:55 – 1:55 PM
• Federal tax credit and incentive developments affecting corporations and pass-through entities
• Research and development (R&D), energy, sustainability, and advanced manufacturing credits
• IRA and OBBBA energy credit developments, including transferability and direct pay elections
• Documentation, substantiation, and audit defense considerations for credit sustainability
• Planning and monetization strategies for tax credits, transferability, and cash flow optimization

Break
1:55 – 2:00 PM

Depreciation, Cost Recovery & Capital Planning  
2:00 – 3:00 PM
• Bonus depreciation, Section 179, and cost recovery developments affecting capital investments
• Cost segregation studies and tax planning opportunities for real estate and fixed assets
• Repair capitalization rules, partial dispositions, and tangible property regulation considerations
• Deferred tax, IRS compliance, and financial reporting considerations related to depreciation strategies
• Practical approaches for improving cash flow and accelerating deductions through cost recovery planning

Break
3:00 – 3:05 PM

Corporate Distributions & Shareholder Transfers
3:05 – 4:05 PM
• Shareholder and corporate-level tax treatment of distributions, redemptions, and liquidations
• Tax consequences of property distributions, stock redemptions, and corporate restructurings
• Reporting, withholding, and compliance considerations involving shareholder transactions
• Planning considerations involving earnings and profits, basis, and gain recognition
• Recent developments affecting corporate distributions and shareholder transfer transactions

Break
4:05 – 4:10 PM

What Corporations Need to Know About BBA  
4:10 – 5:10 PM
• Centralized partnership audit regime developments affecting corporations and investors
• Partnership representative authority, push-out elections, and modification procedures
• Audit exposure, procedural considerations, and IRS examination strategies under BBA
• BBA considerations in acquisitions, partnership agreements, and successor liability planning
• Practical planning considerations involving partnership structures, transactions, and controversy management

Closing Remarks
5:10 – 5:25 PM

DAY TWO AGENDA

Welcome & Opening Remarks
8:45 – 9:00 AM

M&A, Restructuring & Transaction Planning
9:00 – 10:30 AM
• Taxable and tax-free transaction structuring strategies for acquisitions and restructurings
• Section 338 elections, basis step-up planning, and tax attribute considerations
• Tax diligence, indemnities, and key purchase agreement tax provisions
• Net operating loss (NOL), Section 163(j), and post-transaction integration considerations
• Buyer and seller tax planning considerations in mergers, acquisitions, and restructuring transactions

Break
10:30 – 10:35 AM

Tax Controversy, Audits & Dispute Resolution
10:35 AM – 12:00 PM
• Current IRS operational developments, staffing challenges, and enforcement trends
• IRS examination developments and practical strategies for managing audits and controversy matters
• Alternative dispute resolution procedures, Appeals, and Fast Track Settlement considerations
• Practical strategies for managing IDRs, statute extensions, and audit resolution timelines
• IRS use of AI, analytics, and automated systems in audit selection and enforcement initiatives 

Lunch
12:00 – 12:45 PM

Technology, Data & AI in the Corporate Tax Department
12:45 – 2:00 PM
• How AI is transforming corporate tax functions, workflows, and decision-making processes
• Technology primer: AI, automation, and agentic AI systems in the tax function
• Practical applications across tax provision, compliance, transfer pricing, dashboards, and audit readiness
• Governance, controls, ethics, and human oversight considerations for AI-enabled tax functions
• Data analytics, automation, and dashboard strategies for improving reporting, risk management, and operational efficiency

Break
2:00 – 2:05 PM

International Tax & Global Minimum Tax
2:05 – 3:05 PM
• OBBBA international tax changes, FTC developments, tariffs, and evolving IRS enforcement considerations
• OECD Pillar Two framework, including QDMTT, IIR, UTPR, and global minimum tax developments
• GILTI/NCTI developments and interaction with Pillar Two implementation considerations
• OECD Pillar Two “side-by-side” framework and safe harbor developments affecting US-parented multinationals
• Cross-border tax planning, reporting, and compliance considerations for multinational organizations

Break
3:05 – 3:10 PM

State & Local Tax Risk & Opportunities
3:10 – 4:10 PM
• P.L. 86-272 challenges, nexus developments, and remote workforce tax considerations
• Wayfair litigation, marketplace facilitator developments, and evolving sales tax enforcement trends
• Market-based sourcing, apportionment controversies, and constitutional SALT litigation developments
• State taxation of the digital economy, SaaS, and internet-based business activities
• Planning and controversy considerations involving multistate operations and state tax exposure

Break
4:10 – 4:15 PM

Advanced Planning Opportunities & Emerging Issues
4:15 – 5:15 PM
• Section 892 developments involving sovereign wealth funds, effective control, and debt investment structures
• FEOC, specified foreign entity, and foreign-influenced entity rules affecting energy credits and cross-border investment structures
• Practical planning considerations involving foreign ownership, governance rights, and investment structures
• Downward attribution, Section 951B, and controlled foreign corporation (CFC) developments under OBBBA
• Emerging international tax, credit eligibility, and cross-border structuring developments affecting multinational investors

Closing Remarks
5:15 – 5:25 PM

Conference Ends
5:25 PM

Jennifer Black, Managing Director, Citrin Cooperman

Amie Breslow, Of Counsel – Corporate and International Tax Lawyer – M&A, Spin-Offs & Restructurings – Digital Assets, Jones Day

Elizabeth Dengler, Tax Associate, Jones Day

Anne Devereaux, Of Counsel, Gibson Dunn

Rob Drover, Managing Director, CBIZ

Lauren Ferrante, Counsel – State and Local Tax Attorney, Kilpatrick Townsend & Stockton LLP

Benjamin Fryer, Tax Partner, Gibson Dunn

Christopher Hanfling, Partner, Jones Day

Diana Hoshall, Principal, Tax Controversy, BDO

William Kuhlman, Managing Director, CBIZ

Kate Long, Of Counsel, Gibson Dunn

David Oksenhorn, Director, CBIZ

Kate Pascuzzi, Director, Tax Controversy & Procedure, BDO

Larry Rosenblum, Managing Director, CBIZ

Jennifer Sabin, Partner, Gibson Dunn

Tom Smitha, Tax Director, CBIZ

Susan Stanley, US Treasury Advisor, Retired IRS Tax Attache & Retired Director, PwC Tax Services

Lorna Wilson, Partner, Gibson Dunn
 

DAY ONE AGENDA

Welcome & Opening Remarks
8:45 – 9:00 AM

Corporate Tax Update 
9:00 – 10:00 AM
• OBBBA, CAMT, and corporate tax legislative developments affecting multinational businesses
• OECD Pillar Two, GloBE, and global minimum tax implementation updates
• GILTI/NCTI, foreign tax credit, and international tax developments impacting corporate structures and planning
• Practical implications for effective tax rate (ETR), forecasting, and cash tax planning decisions
• Tariff, trade, and cross-border tax developments affecting multinational operations and reporting  

Break
10:00 – 10:05 AM

Update on Transfer Pricing 
10:05 – 11:05 AM
• Recent OECD, regulatory, and economic developments affecting transfer pricing strategies
• Transfer pricing implications of tariffs, supply chain changes, and cross-border operations
• DEMPE functions, intangible property considerations, and controversy risk management
• Documentation best practices, audit readiness, and IRS compliance considerations
• Transfer pricing planning considerations involving customs, benchmarking, and operational restructuring 

Break
11:05 – 11:10 AM

Audit Readiness, Documentation & Risk Management  
11:10 AM – 12:10 PM
• IRS audit readiness strategies and practical approaches for managing examinations
• Documentation best practices for supporting tax positions, credits, and compliance filings
• AI-driven IRS enforcement trends, audit triggers, and automated matching initiatives
• Managing uncertain tax positions (UTPs) and areas of elevated tax risk
• Practical strategies for handling IDRs, statute extensions, Appeals, and audit resolution processes

Lunch
12:10 – 12:55 PM

Tax Credits & Incentives
12:55 – 1:55 PM
• Federal tax credit and incentive developments affecting corporations and pass-through entities
• Research and development (R&D), energy, sustainability, and advanced manufacturing credits
• IRA and OBBBA energy credit developments, including transferability and direct pay elections
• Documentation, substantiation, and audit defense considerations for credit sustainability
• Planning and monetization strategies for tax credits, transferability, and cash flow optimization

Break
1:55 – 2:00 PM

Depreciation, Cost Recovery & Capital Planning  
2:00 – 3:00 PM
• Bonus depreciation, Section 179, and cost recovery developments affecting capital investments
• Cost segregation studies and tax planning opportunities for real estate and fixed assets
• Repair capitalization rules, partial dispositions, and tangible property regulation considerations
• Deferred tax, IRS compliance, and financial reporting considerations related to depreciation strategies
• Practical approaches for improving cash flow and accelerating deductions through cost recovery planning

Break
3:00 – 3:05 PM

Corporate Distributions & Shareholder Transfers
3:05 – 4:05 PM
• Shareholder and corporate-level tax treatment of distributions, redemptions, and liquidations
• Tax consequences of property distributions, stock redemptions, and corporate restructurings
• Reporting, withholding, and compliance considerations involving shareholder transactions
• Planning considerations involving earnings and profits, basis, and gain recognition
• Recent developments affecting corporate distributions and shareholder transfer transactions

Break
4:05 – 4:10 PM

What Corporations Need to Know About BBA  
4:10 – 5:10 PM
• Centralized partnership audit regime developments affecting corporations and investors
• Partnership representative authority, push-out elections, and modification procedures
• Audit exposure, procedural considerations, and IRS examination strategies under BBA
• BBA considerations in acquisitions, partnership agreements, and successor liability planning
• Practical planning considerations involving partnership structures, transactions, and controversy management

Closing Remarks
5:10 – 5:25 PM

DAY TWO AGENDA

Welcome & Opening Remarks
8:45 – 9:00 AM

M&A, Restructuring & Transaction Planning
9:00 – 10:30 AM
• Taxable and tax-free transaction structuring strategies for acquisitions and restructurings
• Section 338 elections, basis step-up planning, and tax attribute considerations
• Tax diligence, indemnities, and key purchase agreement tax provisions
• Net operating loss (NOL), Section 163(j), and post-transaction integration considerations
• Buyer and seller tax planning considerations in mergers, acquisitions, and restructuring transactions

Break
10:30 – 10:35 AM

Tax Controversy, Audits & Dispute Resolution
10:35 AM – 12:00 PM
• Current IRS operational developments, staffing challenges, and enforcement trends
• IRS examination developments and practical strategies for managing audits and controversy matters
• Alternative dispute resolution procedures, Appeals, and Fast Track Settlement considerations
• Practical strategies for managing IDRs, statute extensions, and audit resolution timelines
• IRS use of AI, analytics, and automated systems in audit selection and enforcement initiatives 

Lunch
12:00 – 12:45 PM

Technology, Data & AI in the Corporate Tax Department
12:45 – 2:00 PM
• How AI is transforming corporate tax functions, workflows, and decision-making processes
• Technology primer: AI, automation, and agentic AI systems in the tax function
• Practical applications across tax provision, compliance, transfer pricing, dashboards, and audit readiness
• Governance, controls, ethics, and human oversight considerations for AI-enabled tax functions
• Data analytics, automation, and dashboard strategies for improving reporting, risk management, and operational efficiency

Break
2:00 – 2:05 PM

International Tax & Global Minimum Tax
2:05 – 3:05 PM
• OBBBA international tax changes, FTC developments, tariffs, and evolving IRS enforcement considerations
• OECD Pillar Two framework, including QDMTT, IIR, UTPR, and global minimum tax developments
• GILTI/NCTI developments and interaction with Pillar Two implementation considerations
• OECD Pillar Two “side-by-side” framework and safe harbor developments affecting US-parented multinationals
• Cross-border tax planning, reporting, and compliance considerations for multinational organizations

Break
3:05 – 3:10 PM

State & Local Tax Risk & Opportunities
3:10 – 4:10 PM
• P.L. 86-272 challenges, nexus developments, and remote workforce tax considerations
• Wayfair litigation, marketplace facilitator developments, and evolving sales tax enforcement trends
• Market-based sourcing, apportionment controversies, and constitutional SALT litigation developments
• State taxation of the digital economy, SaaS, and internet-based business activities
• Planning and controversy considerations involving multistate operations and state tax exposure

Break
4:10 – 4:15 PM

Advanced Planning Opportunities & Emerging Issues
4:15 – 5:15 PM
• Section 892 developments involving sovereign wealth funds, effective control, and debt investment structures
• FEOC, specified foreign entity, and foreign-influenced entity rules affecting energy credits and cross-border investment structures
• Practical planning considerations involving foreign ownership, governance rights, and investment structures
• Downward attribution, Section 951B, and controlled foreign corporation (CFC) developments under OBBBA
• Emerging international tax, credit eligibility, and cross-border structuring developments affecting multinational investors

Closing Remarks
5:15 – 5:25 PM

Conference Ends
5:25 PM

Jennifer Black, Managing Director, Citrin Cooperman

Amie Breslow, Of Counsel – Corporate and International Tax Lawyer – M&A, Spin-Offs & Restructurings – Digital Assets, Jones Day

Elizabeth Dengler, Tax Associate, Jones Day

Anne Devereaux, Of Counsel, Gibson Dunn

Rob Drover, Managing Director, CBIZ

Lauren Ferrante, Counsel – State and Local Tax Attorney, Kilpatrick Townsend & Stockton LLP

Benjamin Fryer, Tax Partner, Gibson Dunn

Christopher Hanfling, Partner, Jones Day

Diana Hoshall, Principal, Tax Controversy, BDO

William Kuhlman, Managing Director, CBIZ

Kate Long, Of Counsel, Gibson Dunn

David Oksenhorn, Director, CBIZ

Kate Pascuzzi, Director, Tax Controversy & Procedure, BDO

Larry Rosenblum, Managing Director, CBIZ

Jennifer Sabin, Partner, Gibson Dunn

Tom Smitha, Tax Director, CBIZ

Susan Stanley, US Treasury Advisor, Retired IRS Tax Attache & Retired Director, PwC Tax Services

Lorna Wilson, Partner, Gibson Dunn

DETAILED LEARNING OBJECTIVES

• Identify key developments related to GILTI, NCTI, and foreign tax credit limitations

• Recognize recent legislative and regulatory updates affecting multinational corporations

• Recall changes included in the final stock buyback tax regulations

• Identify selected CAMT proposed regulation developments and IRS notices

• Distinguish between qualified tax incentives and other tax credit structures under GloBE rules

• Recognize emerging global tax environment risks associated with Pillar Two and BEPS 2.0

• Identify practical implications of GloBE rules on forecasting, effective tax rate calculations, and cash taxes

• Recall current IRS corporate and partnership examination focus areas

• Identify common types of intercompany transactions subject to transfer pricing rules

• Recognize the application of the arm’s length principle and arm’s length standard

• Recall key transfer pricing risks associated with multinational operations

• Identify tools used to manage transfer pricing risks and compliance requirements

• Recognize the impact of OECD initiatives, BEPS, and Pillars One and Two on transfer pricing

• Identify DEMPE functions related to intangible property management

• Recall IRS transfer pricing documentation best practices and examination considerations

• Recognize transfer pricing issues associated with tariffs, customs valuation, and global supply chains

• Recognize the general order and procedures involved in an IRS audit

• Recall core documentation standards expected by the IRS for business tax positions

• Identify best practices for organizing and maintaining audit-ready documentation

• Recognize documentation requirements related to deductions, credits, payroll, and employee classifications

• Recall selected documentation requirements associated with OBBB-related tax provisions

• Identify digital asset reporting requirements and related recordkeeping obligations

• Recognize the characteristics and documentation requirements of uncertain tax positions (UTPs)

• Identify qualifying activities and cost pools associated with the R&D tax credit

• Recognize the requirements of the Four-Part Test for qualified research activities

• Recall Section 174 capitalization and amortization changes under OBBBA

• Identify documentation and audit defense best practices for R&D credit claims

• Recognize Form 6765 Section G reporting requirements and related audit risks

• Recall key IRA and OBBBA energy credit provisions and limitations

• Identify requirements associated with credit transfer elections and Direct Pay elections

• Recognize eligibility requirements for clean energy credits, bonus credits, and project timing rules

• Identify the purpose and benefits of cost segregation studies

• Recognize situations in which cost segregation strategies may provide significant tax benefits

• Recall the differences between bonus depreciation and Section 179 expensing

• Identify strategic considerations affecting depreciation and cost recovery planning

• Distinguish between deductible repairs and capital improvements under the Tangible Property Regulations

• Recognize the purpose and benefits of safe harbor elections and partial disposition elections

• Identify deferred tax and financial reporting implications associated with accelerated depreciation

• Recognize risks, compliance considerations, and best practices associated with cost segregation strategies

• Identify the primary types of corporate distributions and shareholder transactions

• Recognize the tax treatment of cash, property, and stock distributions

• Recall the role of earnings and profits in determining dividend treatment

• Distinguish between dividend treatment, return of capital treatment, and sale or exchange treatment

• Identify circumstances in which stock dividends may be taxable or tax-free

• Recognize redemption transactions that may qualify for sale or exchange treatment

• Recall shareholder and corporate tax considerations associated with complete and partial liquidations

• Identify withholding and reporting considerations related to shareholder transactions

• Identify the scope and applicability of the Centralized Partnership Audit Regime (BBA)

• Recognize eligibility requirements and procedures for electing out of BBA

• Distinguish between partnership-level and partner-level adjustments under BBA

• Identify the authority and responsibilities of the Partnership Representative (PR)

• Recognize the treatment of partnership-related items and inconsistent reporting rules

• Identify available modification options for imputed underpayments

• Distinguish between partnership payment of an imputed underpayment and a push-out election

• Recognize collection, assessment, and successor liability considerations under BBA

• Identify competing tax objectives of buyers and sellers in M&A transactions

• Distinguish between taxable stock acquisitions, taxable asset acquisitions, and tax-free reorganizations

• Evaluate the tax consequences of Section 338 elections

• Recognize the requirements for a qualified stock purchase under Section 338

• Identify key tax considerations affecting transaction structure selection

• Understand the treatment and limitations of net operating losses in acquisitions

• Recognize tax issues arising from post-acquisition integration and restructuring activities

• Identify the default classification rules under the check-the-box regulations

• Evaluate the impact of Section 163(j) on acquisition financing transactions

• Recognize key tax provisions commonly negotiated in purchase agreements

• Identify recent operational and workforce changes affecting the IRS

• Recognize how IRS staffing and resource constraints may affect taxpayers and examinations

• Identify common factors that may trigger IRS examination activity

• Recognize key audit focus areas for business and individual taxpayers

• Understand the role of LB&I campaigns in IRS examination strategy

• Identify recent trends affecting the administration and management of IRS examinations

• Evaluate practical strategies for managing IRS examinations effectively

• Distinguish between Fast Track Settlement and Post-Appeals Mediation

• Recognize how the IRS uses data analytics and artificial intelligence in tax administration

• Identify potential risks and opportunities associated with increased IRS automation and AI initiatives

• Identify the role of AI and automation in modernizing the tax function

• Distinguish between traditional automation, artificial intelligence, and agentic AI

• Recognize the stages of the automation maturity curve

• Identify practical applications of AI across the tax lifecycle

• Understand how AI can enhance tax provision, compliance, and transfer pricing processes

• Recognize the benefits of AI-enabled analytics, dashboards, and control testing

• Identify key risks associated with AI adoption in accounting and tax functions

• Understand governance principles and practical AI guardrails

• Evaluate considerations for implementing AI within CPA firms and private industry

• Recognize the evolving role of tax professionals in an AI-enabled environment

• Identify recent US international tax developments affecting multinational enterprises

• Recognize key changes to GILTI/NCTI and other international tax provisions under OBBBA

• Distinguish among the core Pillar Two mechanisms, including the QDMTT, IIR, and UTPR

• Evaluate the impact of the G7 side-by-side framework on US-parented multinational groups

• Assess implementation challenges and unresolved issues related to the global minimum tax regime

• Identify recent state tax nexus developments affecting multistate businesses

• Recognize limitations and challenges to P.L. 86-272 protections in the modern economy

• Evaluate state tax implications of remote workforce arrangements and nonresident employee taxation

• Distinguish between pre-Wayfair and post-Wayfair sales tax nexus developments

• Analyze recent apportionment and market-based sourcing controversies

• Identify key provisions of the Internet Tax Freedom Act (ITFA)

• Assess state taxation issues involving digital products, streaming services, and electronic commerce

• Recognize emerging state tax considerations related to artificial intelligence and SaaS offerings

• Identify key developments affecting foreign government investors under Section 892

• Recognize how effective control and debt investment rules may impact Section 892 eligibility

• Evaluate the practical implications of the final Section 892 commercial activity regulations

• Distinguish between Specified Foreign Entities (SFEs) and Foreign-Influenced Entities (FIEs)

• Identify the impact of FEOC provisions on energy and manufacturing tax credit eligibility

• Recognize the purpose and operation of the material assistance rules

• Understand the restoration of the prohibition on downward attribution under OBBBA and the creation of Section 951B

• Assess emerging international tax planning considerations resulting from IRS administrative changes and recent legislation