TEI-SJSU High Tech Tax Institute (34th Annual)

 November 5 & 6, 2018

Crowne Plaza Cabana
4290 El Camino Real, Palo Alto, CA 

Registration to Open Soon

 Monday, November 5

Time

Topic

Presenters

7:30 - 8:20

Registration & refreshments

 

8:20 – 8:30

Welcome

  • Chris Therrien, Sr. Director - Global Tax Accounting & Compliance, VMWare; President - TEI Santa Clara Valley Chapter
  • Annette Nellen, MST Program Director - SJSU

8:30 - 10:00

International High Technology U.S. Tax Current Developments

Comprehensive review of developments relevant to high tech companies.

  • Jim Fuller, Partner - Fenwick & West LLP

10:00 – 10:20

Break

 

10:20- noon

Decisions, Decisions – Capital Structures after TCJA

The Tax Cuts and Jobs Act changes rules on depreciation, interest expense deduction, NOLs, FTCs and more. International changes including GILTI and anti-hybrid also warrant reconsideration of past decisions. In addition, rate reductions, the new QBI deduction and other changes require rethinking of the choice of entity analysis. Finally, how do state rules affect decision-making?

 

Noon - 12:40

Lunch 

 

12:40 - 1:30

Luncheon Speaker

  • TBD

1:35 - 3:15

 

BREAKOUT A
Say Goodbye? Executive Comp & Fringe Benefits Planning 
What is no longer deductible after the Tax Cuts and Jobs Act and how does the structure of meals, transit and other benefits affect the outcome? Who can offer qualified equity grants and what are the pros and cons?

 

BREAKOUT B
Don’t Get Beat by the BEAT
The Tax Cuts and Jobs Act changes to address base erosion and tax abuse brings us BEAT (base erosion and anti-abuse tax). With the revised international tax regime, the BEAT works in intended, but also unintended ways.  And, what is the affect under ASC 740 and state taxation?

 

3:15 - 3:30

Break

 

3:30 - 5:15

 

BREAKOUT C
Locating Intangibles – Generating and Using FDII
The TCJA brings a new perspective on IP location planning due to foreign-derived intangible income (FDII). What is the effect on planning and tax rates, as well as the effect on financial statements and state taxes?

 

 

BREAKOUT D
Can Software or AI Help Deal with the TCJA?
What new tools will help with compliance with new rules brought by the Tax Cuts and Jobs Act? What is needed for E&P tracking? Considerations of integration with GL and other systems as well as state tax compliance will be addressed as well.

 
 
Tuesday, November 6

Time

Topic

Presenters

7:30 - 8:15

Registration & coffee

 

8:15 – 9:15

Accounting for Income Taxes

How to be sure nothing is missed in dealing with the TCJA? Other new GAAP guidance will also be covered.

 

 

9:15 - 10:30

 

BREAKOUT E
Getting Credit – Generating and Using Foreign Tax Credits after the TCJA
A review of how the TCJA affects existing credits and how they will be generated and used thereafter. Traps and opportunities to also be addressed.

 

 
BREAKOUT F

Cryptocurrency, ICO and Whatever Else is New
New types of assets might replace established practices. Along with defining these assets, a review of their relevance to equity financing, M&A, funds transfers and more, as well as tax considerations will be addressed.

 

10:30 – 10:45

Break

 

10:45- noon

 

BREAKOUT G
Transfer Pricing Transformations
A review of what’s new after the TCJA and its changed regime for international taxation, as well as a rate cut. Notable changes and actions in other countries will also be covered.

 

BREAKOUT H
Keep Your Head in the Clouds
What new perspectives do we have from the US, Germany, other countries, as well as the states. What is the implication under FDII and BEAT?

 

12:00 - 12:40

Lunch

 

12:40 - 1:25

Luncheon Speaker

  • TBD 

1:30 - 3:00

 

BREAKOUT I
M&A Meets the TCJA – Who Wins?
What is changed and what cautions and opportunities exist in searching for and completing mergers and acquisitions in light of TCJA provisions?

 

BREAKOUT J
Digital Presence and the EU
Coverage of new EU directives and why they were issued and what transactions and taxpayers are affected. Compliance tips are also addressed.

 

3:00 - 3:15

Break

 

3:15 - 4:30

Federal Tax Controversy – New Approaches

What is new at the IRS and LB&I – a look at examinations and the TCJA, new exam practices including continued implementation of campaigns, and how data analytic tools are being used.

 

4:30 - 5:30

Domestic and Multistate Update

Developments of relevance to high tech companies including reaction to the TCJA, the US Supreme Court’s decision in the Wayfair case, California update and key guidance and areas to watch at the state and multistate levels.