Key topics being addressed by our expert speaker panel include:
- Understanding the new regulations incorporating the guidance provided in Notice 2010-60 and supplemented by Notice 2011-34 providing further guidance on implementing Chapter 4 (Expected by December 31, 2011)
- Examining IRS notice 2011-53 released in July 2011
- Understanding the practical difficulties in implementing specific aspects of the Chapter 4 rules
- The need for significant modifications to the information management systems of FFIs, withholding agents, and the IRS
- Participating FFI Due Diligence
- Private banking FATCA guidance
- Passthru payments
- Leveraging QI experience for FATCA implementation
- Making sense of FATCA in the QI context
- Identifying FATCA risks and assessing compliance costs
Special Address by the IRS:
FATCA Regulations: Insight from the IRS’ Perspective
Delivered by:
Danielle Nishida, Attorney, Office of Chief Counsel, International, Internal Revenue Service
Biography
Danielle Nishida joined the Internal Revenue Service, Office of Chief Counsel, International, in April 2009. She practices in income tax withholding and Subpart F, and is a principal draftsperson of the recent proposed regulations and other guidance under chapter 4 (FATCA). Prior to joining the Internal Revenue Service, she was an attorney with Burt, Staples, and Maner, LLP. Danielle is a graduate of Georgetown University (L.L.M, Taxation), Southwestern Law School (J.D.), and the University of California at Santa Barbara (B.A.).
John Sweeney, Senior Technical Reviewer, Office of Chief Counsel, International, Internal Revenue Service
Biography
John Sweeney is the Senior Technical Reviewer in Branch 2 of the Office of Associate Chief Counsel (INTL) at the IRS. He is currently working on various withholding issues and projects, most notably the guidance project covering new chapter 4 of the code and Section 502 of the HIRE Act dealing with registered bond requirements. Previously, he worked as a senior manager in KPMG LLP’s information reporting practice, and before that had worked for almost ten years at IRS as an attorney in LMSB Counsel, Financial Services. He had previously held various positions in IRS’s examination division, including over two years as the IRS’ Foreign Banking Specialist. He received a J.D. and an L.L.M. degree (in taxation) from New York Law School and is a certified public accountant.
Masterclass Facilitator:
Featured Speakers:
Joshua Fine,
Senior VP,
Brown Brothers Harriman
Lorraine White,
Senior Vice President - International Tax Service,
Northern Trust
David Treitel,
Tax Director,
US Tax & Financial Services Ltd
John Staples,
Director,
Burt, Staples & Maner LLP
Ralph Cunningham,
Managing Editor,
International Tax Review
Denise M. Hintzke,
Global Tax Leader,
Foreign Account Tax Compliance, Deloitte Tax LLP
Jennifer Sponzilli,
Partner,
KPMG
Philippe Sebagh, Chairman,French Investment Funds Association FATCA Working Group
Sophie Biourge,
Director, Product Management,
Euroclear
Peter Grant,
Executive Director – Tax Manager,
JP Morgan
Jay Krause,
Partner,
Withers LLP
James Guthrie,
Director of Operational Tax, FS EMEIA,
Ernst & Young
Cyrus Daftary, Partner, Burt, Staples & Maner LLP
Andrew Wilson, Managing Director, QI Solutions
Peadar McCabe, Tax Planning Manager, Santander UK
Jorge Morley-Smith, Head of Tax, Investment Management Association
Marnin Michaels, Partner, Baker & McKenzie
Simon Leach, Director, Banking & Capital Markets Tax Group, PwC
Dana Ward, Tax Partner, Grant Thornton LLP
Richard Hinton, Director, Investment Management Audit Department, KPMG
Philip Kerfs, Advisor, Centre for Tax Policy and Administration,OECD
Manja De Goede Kisman,
Global QI Coordinator,
ABN AMRO Clearing Bank
Organisations who attended Osney Media’s Withholding Tax on US-Sourced Income Congress previously have included:
IRS/Treasury • Nordea • JP Morgan • BNY Mellon • Standard Chartered • Ernst & Young • Deloitte • PricewaterhouseCoopers • FISCO • Euroclear • Barclays Global Investors • CTI • Fortis • Barclays Bank • Citibank • Goodbody Stockbroker • Kleinwort Benson • Caceis Bank Luxembourg • HSBC Securities Services• Burt, Staples & Maner, LLP • Swift • Brewin Dolphin • DnB NOR • Jyske Bank • Société Générale • BNP Paribas • Deutsche Bank • Investec • Collins Stewart • KAS BANK • Daiwa Securities • ING Bank • Rensburg Sheppards • Rathbones • Pershing • LODH • Bank Guzman • Charles Stanley • ABN Amro • TD Waterhouse
