Corporate Tax Strategies & Compliance Virtual Conference
Overview
Corporate tax teams are navigating a rapidly shifting landscape shaped by new legislation, heightened enforcement, and growing expectations for strategic insight and transparency. This two-day virtual conference delivers a comprehensive, practical view of today’s most critical corporate tax planning and compliance issues, from legislative updates and core planning strategies to credits and incentives, audit readiness, and transaction structuring. Through expert-led sessions and real-world guidance, attendees will gain actionable tools to manage effective tax rates, improve cash tax forecasting, reduce risk exposure, and align tax strategy with broader business objectives in an increasingly complex regulatory environment.
DAY ONE AGENDA HIGHLIGHTS
• Corporate Tax Update
• Update on Transfer Pricing
• Audit Readiness, Documentation & Risk Management
• Tax Credits & Incentives
• Depreciation, Cost Recovery & Capital Planning
• Corporate Distributions & Shareholder Transfers
• What Corporations Need to Know About BBA
DAY TWO AGENDA HIGHLIGHTS
• M&A, Restructuring & Transaction Planning
• Tax Controversy, Audits & Dispute Resolution
• Technology, Data & AI in the Corporate Tax Department
• International Tax & Global Minimum Tax
• State and Local Tax Risk & Opportunities
• Advanced Planning Opportunities & Emerging Issues
Agenda
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
Speakers
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