8.30  
Registration and Breakfast

9.00  
Welcome to US Tax Day 2.0

9.10  
US legislative updates related to International Tax and Transfer Pricing

10.15
Coffee break

10.30
Key international provisions for operating in the US

• BEAT, FDII, CAMT, 163(j), etc.
• FDII prepayment planning
• Cash repatriation (treaty considerations, FIRPTA – Foreign Investment in Real Property Tax Act)
• US restructuring

11.15
Transfer Pricing in the US

• US specific Transfer Pricing Concepts
  - Services Cost Method
  - Cost Sharing Arrangements
  - Intercompany Financing – Applicable Federal Rates
• US expansion and integration strategies for Transfer Pricing

12.00
Lunch break, light lunch served at KPMG House

12.45
Navigating the US tax scene in Alternative Investments

• Continuing Aftermath of YA Global case: Implications for Alternative Investments
• Living with Guidance for Qualified Foreign Pension Funds, Sovereign Investors, and Domestically Controlled REITs
• US Tax Policy Landscape – Aftermath of US Elections
• Corporate Alternative Minimum Tax (CAMT) Update
• Inflation Reduction Act Credits – State of Play

14.15
Wrap-up of the US Tax Day