2015 High Tech Tax Institute

Monday, November 9, 2015

Time Topic Presenter(s)

7:30-8:15 AM

Registration and Refreshments


8:15-8:30 AM


  • Neil J. Young (President, TEI Santa Clara Valley Chapter)
  • Eli Dicker (Executive Director, Tax Executives Institute, Inc.)
  • Annette Nellen (MST Program Director, San José State University)

8:30-10:10 AM

International High Technology U.S. Tax Current Developments [pdf]: Comprehensive review of developments relevant to high tech companies.

10:10-10:30 AM



10:30 AM-12 PM

Practical Consequences of BEPS [pdf]: A review of the BEPS Action Items and key issues in them for high tech companies. How country-by-country reporting is addressed in selected countries and the transfer pricing relevance.

12-12:40 PM



12:40-1:35 PM

Luncheon Speaker [pdf]

  • Joseph M. Mikrut  (Principal, Capitol Tax Partners)

1:40-3:30 PM

European Union Hot Topics [pdf]: What’s new and hot in the EU? A look at patent or innovation boxes, the UK diverted profits tax, state aid issues, VAT and digital services, reaction to the OECD BEPS activities, and more.

  • Mark O’Sullivan  (Partner, Matheson)
  • Paul Rutherford (Partner, DLA Piper, United Kingdom)

3:30-3:45 PM



3:45-5:15 PM



Subpart F [pdf]: Developments and issues regarding subpart F including substantial contribution and branch rule issues.



Cloud Activities and Issues under Sections 41 and 199 [pdf]: How to address questions that can arise for the research tax credit and manufacturing deduction by new economy transactions such as variations on cloud computing including SaaS.

Tuesday, November 10, 2015

Time Topic Presenter(s)

7:30-8 AM

Registration and Refreshments


8-9 AM

Accounting for Income Taxes [pdf]: Update and guidance on issues involving stock options and other equity compensation, employee mobility and tax reform.

9-10:15 AM

State Tax Reform [pdf]: Why are states honing in on tax haven and transfer pricing matters? What reforms are underway by the states and MTC?

10:15-10:30 AM



10:30 AM-12 PM

Repatriation Strategies versus Reinvestment Overseas [pdf]: Discussion will include administrative developments, planning ideas such as sale of IP and holding companies, APB 23 considerations and more.

12-12:40 PM



12:40-1:25 PM

Luncheon Speaker

  • Heather C. Maloy (Tax Controversy Leader, EY; Former IRS Commissioner for Large Business & International (LB&I) Division)

1:30-3 PM

IRS Developments and Examination Strategies [pdf]: An update on the LB&I organizational structure, the Quality Exam Process, international procedures and field coordination, competent authority, and mediation practices.

3-3:15 PM



3-4:30 PM

What’s Hot and What’s New in M&A [pdf]: Cross-border M&A (including inversions), PE Firm buyouts of technology companies, spin-offs, NOL planning, IPO structuring, BEPS, and related topics.”

4:30-5:30 PM

Domestic and Multistate Update [pdf]: Developments of relevance to high tech companies including internal use software regulations, other research credit developments, California update and key guidance and areas to watch at the state and multistate level including sourcing and apportionment.

  • Don Corbett (Partner, Grant Thornton - Federal)
  • John Clausen (SALT Director, Moss Adams - State)