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 Landscape & Legislative 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 Landscape & Legislative Update
9:00 – 10:00 AM
• Recent federal and international corporate tax developments affecting compliance, planning, and reporting
• Key legislative, regulatory, and IRS enforcement updates impacting corporate taxpayers
• International tax considerations, including foreign income, tax credits, and ownership rules
• Practical implications for forecasting, effective tax rate (ETR), and cash tax planning
Break
10:00 – 10:05 AM
Update on Transfer Pricing
10:05 – 11:05 AM
• Core transfer pricing principles, intercompany transactions, and arm’s length requirements
• Recent global, regulatory, and economic developments affecting transfer pricing strategies
• Documentation best practices, risk management, and IRS compliance considerations
• Transfer pricing implications of tariffs, supply chain changes, and cross-border operations
Break
11:05 – 11:10 AM
Audit Readiness, Documentation & Risk Management
11:10 AM – 12:10 PM
• IRS audit readiness strategies and the current enforcement environment
• Documentation best practices for tax positions, credits, and deductions
• Managing uncertain tax positions and areas of elevated tax risk
• Practical approaches to reducing audit exposure and strengthening compliance
Lunch
12:10 – 12:55 PM
Tax Credits & Incentives
12:55 – 1:55 PM
• Federal tax credits and incentives available to businesses across industries
• R&D, energy, and other high-value credits: qualification and planning considerations
• Documentation, substantiation, and audit readiness for credit claims
• Strategies for integrating credits into tax planning, cash flow, and financial reporting
Break
1:55 – 2:00 PM
Depreciation, Cost Recovery & Capital Planning
2:00 – 3:00 PM
• Cost segregation and depreciation strategies to improve cash flow and tax efficiency
• Bonus depreciation, Section 179, and capitalization planning considerations
• Asset disposition, repair, and cost recovery opportunities for businesses
• Financial reporting, deferred tax, and IRS compliance considerations related to depreciation
Break
3:00 – 3:05 PM
Corporate Distributions & Shareholder Transfers
3:05 – 4:05 PM
• Tax treatment of corporate distributions, redemptions, and liquidation transactions
• Key distinctions between dividend and sale/exchange treatment
• Shareholder and corporate tax consequences of ownership changes and distributions
• Withholding, reporting, and compliance considerations for corporate transactions
Break
4:05 – 4:10 PM
What Corporations Need to Know about BBA
4:10 – 5:10 PM
• Centralized partnership audit regime rules and their impact on corporations with partnership interests
• Key BBA filing, reporting, and election considerations
• Audit procedures, collections, and partnership-related compliance requirements
• Practical planning considerations for transactions, deal structures, and audit exposure
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
• Tax considerations in mergers, acquisitions, divestitures, and restructurings
• Transaction structuring strategies, including elections and tax-free transactions
• NOL utilization, interest limitation rules, and restructuring planning considerations
• Aligning tax strategy with deal objectives, integration, and transaction timelines
Break
10:30 – 10:35 AM
Tax Controversy, Audits & Dispute Resolution
10:35 AM – 12:00 PM
• Current IRS enforcement environment and examination priorities
• Audit trends and practical considerations for managing IRS examinations
• Dispute resolution options, including alternative resolution tools
• How AI and data analytics are shaping IRS audit selection and enforcement
Lunch
12:00 – 12:45 PM
Technology, Data & AI in the Corporate Tax Department
12:45 – 2:00 PM
• How AI and automation are transforming modern tax functions and workflows
• Key technology concepts, including AI, automation, and agentic AI systems
• Practical applications across tax provision, compliance, transfer pricing, and audit readiness
• Governance, ethics, and workforce implications of emerging tax technologies
Break
2:00 – 2:05 PM
International Tax & Global Minimum Tax
2:05 – 3:05 PM
• Recent U.S. international tax developments and enforcement challenges
• OECD Pillar Two framework, including scope, mechanisms, and timelines
• Global minimum tax “side-by-side” system and related safe harbor updates
• Practical implications for multinational tax planning, compliance, and reporting
Break
3:05 – 3:10 PM
State & Local Tax Risk & Opportunities
3:10 – 4:10 PM
• Evolving SALT nexus standards and remote workforce tax implications
• Key developments in market-based sourcing, apportionment, and sales tax nexus
• State conformity challenges and taxation of the digital and AI-driven economy
• Practical audit, compliance, and planning considerations for multistate taxpayers
Break
4:10 – 4:15 PM
Advanced Planning Opportunities & Emerging Issues
4:15 – 5:15 PM
• Advanced international tax planning developments under Section 892 and related regimes
• Foreign investment, FEOC/SFE/FIE rules, and implications for tax credits and structures
• Controlled foreign corporation (CFC) planning, attribution rules, and cross-border compliance considerations
• Emerging IRS, Pillar Two, and regulatory developments impacting multinational tax strategy
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