Attention:

Tax Practice Essentials: Can't Touch This - The Basics of Intangibles


Level: Advanced
Runtime: 91 minutes
Recorded Date: February 12, 2020
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Agenda


        • Identifying Intangibles
        • Valuing Intangibles Pre-TCJA
        • Valuing Intangibles Post-TCJA
        • International Responses to Taxing Intangibles and the Digital Economy
        • Alternative US Methods for Taxing Intangibles
                - GILTI (Global Intangible Low-Taxed Income)
                - FDII (Foreign-Derived Intangible Income)

Runtime: 1 hour, 31 minutes
Recorded: February 12, 2020

Description

In the modern economy, more and more value is derived from intangible assets. As the value of these assets increase, so does the complexity surrounding their taxation. Panelists will cover areas such as transfer pricing (including BEPS), Foreign-Derived Intangible Income (FDII), and Global Intangible Low-Tax Income (GILTI) regimes created by the Tax Cut and Jobs Act.

This program was recorded on February 12th, 2020.

Provided By

American Bar Association

Panelists

Nick Zemil

Manager
PricewaterhouseCooper

Nick Zemil is a Manager at PwC in charge of the Washington National Tax Services. He is also an Adjunct Professor at the University of Maryland Robert H. Smith School of Business.

Nick received his JD at the University of Virginia School of Law in 2013.

Lisandra Ortiz

Senior Associate
Miller & Chevalier Chartered

Lisandra Ortiz is a Senior Associate in the Tax Department and centers her practice on federal tax controversy matters, particularly those related to international tax and transfer pricing.

Ms. Ortiz was a key member of the team representing a taxpayer in a multi-billion dollar transfer pricing case before the U.S. Tax Court, where she managed discovery; worked closely with the client to develop facts; drafted pleadings, briefs, stipulations, and discovery responses and requests; presented a fact witness at trial and prepared others for their testimony; and worked with expert witnesses to develop reports and testimony. In addition, Ms. Ortiz has experience handling tax refund litigation cases before the U.S. Court of Federal Claims.

Beyond the courtroom, Ms. Ortiz's practice encompasses advising clients on the resolution of cross-border double taxation disputes through the competent authority process, negotiating advance pricing agreements between the IRS and other tax authorities, and representing clients in transfer pricing audits before the IRS.

While attending Georgetown University Law Center, Ms. Ortiz served as the Executive Notes Editor for The Tax Lawyer and was awarded the Sewall Key Award for Best Scholastic Record in Taxation.

Jorge M. Oben

Attorney, Office of Chief Counsel
IRS

Jorge Oben is an Attorney in the Office of the Chief Counsel at the IRS.

Drew A. Cummings

Associate
Morgan, Lewis & Bockius LLP

Drew A. Cummings assists taxpayers at all stages of federal income tax controversy matters. Drew’s primary areas of experience include transfer pricing, international tax issues, and litigation practice and procedure. He spends the majority of his time representing taxpayers before federal courts, including the US Tax Court and US District Courts. Drew also counsels and represents taxpayers during IRS examinations and appeals.

Before joining Morgan Lewis, Drew clerked at the US Tax Court for Judge Albert G. Lauber. He holds an LL.M. in taxation from Georgetown University Law Center, where he attended on a merit scholarship. While in law school, he received the Hinkle Elkouri Law Firm Tax Procedure Award for his scholastic achievement and lead a Volunteer Low Income Tax Assistance (VITA) site. As an undergraduate, he competed on his school’s intercollegiate policy debate team.


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