Layla Asali will speak at the Philadelphia Tax Conference on October 30, 2026. Asali will present, as a part of the panel, "International Tax Update," which will include an update on IRS priorities and guidance. Panelists will cover:    

• Open OBBBA issues under Section 174 (amortization of R&D expenses) and Stewardship
• A review of proposed regulations under Sections 898 (tax years of foreign corporations) and Section 951(a)(1) (determining a U.S. shareholder’s pro rata share of income inclusion under Subpart F)
• A consideration of recent holdings in Varian Med. Systems, Inc. v. Comm’r, and Siemens Med. Sol. USA Inc. v. Comm’r