On May 27, 2015 the IFA (International Fiscal Association) USA Atlanta Region Chapter held a seminar on various international tax issues. Marc Schwartz was invited to participate in a panel discussing Internal Revenue Code 956, Subpart F and related repatriation issues impacting both individuals and companies. Other items the panel discussed include APB 23, deferral vs. non-deferral and the ever-increasing use of anti-abuse rules by the Internal Revenue Service.
Two other panels focused on M&A structuring and current global tax developments including those related to the OECD BEPS initiative and changes to the US Model Treaty. After Schwartz International’s Richard Hartnig participated as a panelist last year, it was a privilege for the firm to have a speaker back-to-back years.
For more information on IFA, please see https://www.ifausa.org/members/group.aspx?id=146458.