ABA Virtual 2021 May Tax Meeting
Layla Asali, Jorge Castro, and Loren Ponds will speak at the ABA Virtual 2021 May Tax Meeting.
On May 10, Asali will participate in the panel discussion, "I Don't Know What I Don't Know: M&A Issues Beyond Subchapter C." This panel will address issues that sub-C lawyers might not be aware of when advising a client on an M&A transaction. Panelists will also discuss issues related to accounting methods, installment sales, foreign currency hedging and related integration issues, BEAT, possible gain recognition agreement triggers, the impact on certain transfer pricing arrangements and foreign tax credits.
Ponds will present, as part of a panel, "Overlay of Potential International Tax Reform and OECD Pillars I and II," on May 12. This panel will examine the potential influence of OECD Pillars I and II on tax reform in the United States and possible interactions of the regimes, examining issues such as country-by-country determinations, minimum taxes based on book income, and the continued relevance of foreign tax credits.
On May 12, Castro will speak on the panel, "Where, Oh Where Could My Refund Be?" This panel will discuss various topics with respect to seeking a refund including informal and formal refund claims, protective refund claims, and tentative refund claims. Panelists will highlight particular issues and procedures in seeking a refund during the COVID pandemic.