Virtual

39th Annual TEI-SJSU High Tech Tax Institute (2023)

Date: Nov. 29 - 30, 2023

Time: 8:30 – 11:55 a.m. PT

CPE: 12

Overview

The SJSU MST Program manages and co-sponsors three annual tax conferences. The hallmark High Tech Tax Institute started in 1988, is a two-day conference held each November. Speakers and attendees come from around the world. Leading-edge topics relevant to high-tech companies and their tax professionals are addressed by nationally and internationally recognized practitioners and government representatives who have practical experience in implementation. The learning opportunities make the annual TEI-SJSU High Tech Tax Institute an invaluable educational tax experience for accountants, attorneys, and corporate representatives who serve high-technology businesses.

This one-of-a-kind conference will help you stay on top of new rules and issues facing high tech businesses. Don’t miss it.

This is a recording of much of the live conference held on November 6 & 7, 2023 in Palo Alto; speakers will be monitoring the Q&A box at the virtual event.

IRS employees may contact the CalCPA Customer Success Team at (800) 922-5272 to register and receive a discount

Product Code
1000002544
Credit Type
CPE: 12
CPE-Technical: 12
Format
Virtual
NASBA Field of Study
Taxes
Level of Difficulty
Update
Prerequisites
None
Advance Preparation
None

Learning Objectives

Recognize key tax issues of relevance to corporate tax departments, accounting and law firms, the IRS and academics.

Agenda

Welcome/Opening Remarks
Speaker(s)
Annette Nellen
Howard Schneck
Rangapriya Kannan

International High Technology U.S. Tax Current Developments
Comprehensive review of developments relevant to high tech companies.
Speaker(s)
David Forst Julia Ushakova-Stein

Morning Break

Capitalizing R&D Expenditures is Odd For Many Reasons and Tax Rules
The TCJA change to capitalize and amortize R&D after 2021 not only affects R&D expenses under Section 174, but also under Section 1297 and for GILTI. There can also be AMT effects. This program covers how to identify R&D to be capitalized, the meaning of software development under new 174(c)(3) and all of the tax rules this change affects.
Speaker(s)
Tony Coughlan Kevin Edward Dangers Travis Riley Carolyn Smith Driscoll
Paul F Coates

Lunch Break

M&A Deals – What’s New?
This panel will look at unique issues for buyers of partnerships (BA, buying both partnership interests and stock of partner blockers), buying in or out of a consolidated group (ratable elections, -6 liability, unified loss rules), corporate AMT M&A issues and considerations of the stock buyback excise tax.
Speaker(s)
Myra Sutanto Shen
Jeremy Aron-Dine
Eileen Marshall
Sarah-Jane Morin
Bryan Keith

Afternoon Break

Federal Tax Controversy – Where is the $80 Billion?
How will the IRS plan on how to use $80 billion over ten years affect examinations, appeals and taxpayer services. How is the IRS onboarding new personnel? What Covid operational changes remain, such as remote exams and e-signatures. What’s new procedurally due to legislation of the past five years?
Speaker(s)
Robert J. Kovacev
Roger J Benesch
Paul DiSangro
Chris Murphy
Kathleen M Kruchten
Peter Rock
Stephen Shee

Domestic and Multistate Tax Update
Key updates for the past year relevant to tech companies and not covered elsewhere in our program.
Speaker(s)
Dana Louise Lance
Annette Nellen

Accounting for Income Taxes
The latest developments and issues including dealing with corporate AMT and new treatment for R&D expenditures.
Speaker(s)
Kelly Renee Georgiou
Jared Steven Huish
Emily Caroline Cashwell
John Joseph Schneider III

We Just Can’t Get Enough of Pillar 2
What progress are other countries making in implementing Pillar 2, what is the effect on international tax planning, and what is going on in the U.S. that companies should be ready for.
Speaker(s)
Dennis Chad Hungerford
Robin Hart
David Wachutka
Mike Wittig

Morning Break

Focusing on PFICs
This panel will focus on regulatory and statutory issues, the entity versus aggregate approach for calculations, Fintech guidance, and more.
Speaker(s)
Joseph Calianno
Surhbi Bordia
William Skinner
Dan McCall

Faculty

Jeremy Aron-Dine

Roger J Benesch

Surhbi Bordia

Joseph Calianno

Joe Calianno is a Managing Director in the US National Tax practice in the Washington D.C. office. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring. Prior to joining Andersen, Joe spent several years as a partner at BDO and Grant Thornton, where he served as the International Technical Tax Practice Leader in both firm’s national tax offices.Joe also p...

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Emily Caroline Cashwell

Paul F Coates

Tony Coughlan

Tony has more than 25 years of experience in tax planning, tax controversy, and tax policy, including 10 years on the U.S. Senate Finance Committee staff as senior tax counsel. He has extensive experience in the Section 41 research credit, the Section 174 R&E deduction, international tax, payroll tax, real estate tax, and statutory construction. During his time with the Senate Finance Committee, he advised on corporate and international tax le...

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Kevin Edward Dangers

Kevin Dangers is a Partner in Ernst & Young’s West Region Quantitative Services group, and has specialized in providing federal tax solutions and services to clients in the high-technology, financial services and Fintech, manufacturing, and consulting service industries for over twenty-five years.Kevin specializes in research credit and tax accounting methods, including income and expense recognition, ASC 606 and capitalization issues. Kevin h...

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Paul DiSangro

Paul DiSangro is a trusted advisor to CFOs and tax directors in San Francisco and Silicon Valley. He has 25 years of experience across a range of industries including software, technology, financial services (including fintech), insurance, energy, media, pharma, biotech and retail. He prides himself on delivering value with practical solutions. Paul’s experience includes: Exams, administrative appeals, and litigation with federal and state ag...

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David Forst

David focuses on international corporate taxation. David has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. David is included in Euromoney’s Tax Advisors Expert Guides (World’s Leading Tax Advisors, World’s Leading Transfer Pricing Advisors and was named one of the Top 30 U.S. Tax Advisors). He is also in The Legal 500 Hall of Fame and is regularly recognized in the Law and Business Research’s Internati...

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Kelly Renee Georgiou

Kelly Georgiou is a Senior Manager in Business Tax Services with nearly 15 years of experience at Deloitte Tax, serving corporate tax clients ranging from emerging growth to large publicly-traded multinationals. Kelly serves clients primarily in the Technology industry with experience also in the Chemical & Specialty Materials industry. Kelly holds a Masters in Taxation degree from San Jose State University.

More about Kelly Renee Georgiou

Robin Hart

Jared Steven Huish

Dennis Chad Hungerford

Chad Hungerford is a partner in Deloitte Tax LLP’s international tax practice and is based out of San Jose. He has more than 14 years of experience advising US based multinational companies in regards to the tax planning, tax accounting, and tax reporting obligations associated with their international footprint. Chad is a national resource for the taxation of the cloud, global developments with respect to digital taxation, and international i...

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Rangapriya Kannan

Bryan Keith

Robert J. Kovacev

Kathleen M Kruchten

Kathy currently serves as the Director, Western Compliance Practice Area (WCPA) in the Large Business and International (LB&I) Division of the Internal Revenue Service. In this role, Kathy provides leadership on the full range of pre-filing, filing, and post-filing programs and activities for large and mid-size businesses in Washington, Oregon, Alaska, Hawaii, Idaho, Montana, Wyoming, California, Nevada, Utah, Colorado, Arizona, Kansas, Texas,...

More about Kathleen M Kruchten

Dana Louise Lance

Eileen Marshall

Dan McCall

Sarah-Jane Morin

Chris Murphy

Annette Nellen

Annette Nellen is a professor in and director of San José State University's graduate tax program (MST), teaching courses in tax research, accounting methods, property transactions, employment tax, ethics, and tax policy. Annette is active in the tax sections of the AICPA (including as a former chair of the Tax Executive Committee), ABA and California Lawyers Association. In 2020-2021, she served on the AICPA-NASBA CPA Evolution Education Advi...

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Travis Riley

Travis has provided research tax credit studies to companies claiming R&D credits since 2006. He is a leader in the firm’s R&D practice in California, helping both companies and business owners save millions of dollars in taxes each year.Travis has significant experience helping companies identify, increase, document, and support claims related to R&D tax credits, orphan drug credits, and other R&D incentives. He works with taxpayers in a wide...

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Peter Rock

Howard Schneck

John Joseph Schneider III

Stephen Shee

William Skinner

Will Skinner focuses his practice on U.S. international corporate tax, including the full range of international tax issues such as subpart F and deferral structures, foreign tax credit planning, transfer pricing, IP migration, and structuring IP ownership within a corporate group, internal restructurings and cross-border M&A, and tax treaties and other inbound tax planning. His clients have ranged from Fortune 500 companies tostart-up and clo...

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Carolyn Smith Driscoll

Carolyn is a director in Cherry Bekaert’s Tax Credits and Incentives Advisory practice. She is responsible for sales, project management and technical expertise. Carolyn’s focus in on state and federal research and development tax credits, employee retention credits, cost segregation studies as well as a variety of energy incentives. She also participates in tax controversy at both the federal and state levels.Carolyn’s primary focus is to sav...

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Myra Sutanto Shen

Julia Ushakova-Stein

Julia advises on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound), mergers and acquisitions, and transfer pricing. She represents clients from a diverse set of industries and geographic areas. She has represented a number of Fortune 500 companies in U.S. federal income tax matters and has successfully represented clients in federal tax controversies at all levels.Julia was nam...

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David Wachutka

Mike Wittig

39th Annual TEI-SJSU High Tech Tax Institute (2023)

Overview

Product Code

Credit Type

Format

NASBA Field of Study

Level of Difficulty

Prerequisites

Advance Preparation

Learning Objectives

Agenda

8:30 – 8:35 a.m. PT

Welcome/Opening Remarks

Speaker(s)

8:35 – 10:20 a.m. PT

International High Technology U.S. Tax Current Developments

Speaker(s)

10:20 – 10:30 a.m. PT

Morning Break

10:30 a.m. – 12 p.m. PT

Capitalizing R&D Expenditures is Odd For Many Reasons and Tax Rules

Speaker(s)

12 – 12:30 p.m. PT

Lunch Break

12:30 – 1:45 p.m. PT

M&A Deals – What’s New?

Speaker(s)

1:45 – 2 p.m. PT

Afternoon Break

2 – 3:30 p.m. PT

Federal Tax Controversy – Where is the $80 Billion?

Speaker(s)

3:30 – 4:30 p.m. PT

Domestic and Multistate Tax Update

Speaker(s)

8:30 – 9:30 a.m. PT

Accounting for Income Taxes

Speaker(s)

9:30 – 10:45 a.m. PT

We Just Can’t Get Enough of Pillar 2

Speaker(s)

10:45 – 10:55 a.m. PT

Morning Break

10:55 – 11:55 a.m. PT

Focusing on PFICs

Speaker(s)

Faculty