International Tax Series: International Tax Controversy Update

This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine.

Speakers:

Elizabeth Kanyer, Associate, Latham & Watkins LLP

James Kelly, Deputy Associate Chief Counsel, International (Controversy & Litigation), Office of the Associate Chief Counsel (International), IRS

Starling Marshall, Partner, Crowell & MoringLLP

C. Terrell Ussing, Partner, Gibson, Dunn & Crutcher LLP

Steve Dixon, Partner, Steptoe LLP (Moderator)