In each of the next two weeks, I will be speaking (probably for about 15 minutes each time) on an international tax panel that is meeting in the NYC area. In each case, I plan to post a version of my remarks here afterwards.
First, next Friday, October 28, NYU Law School will be hosting an event (as I've mentioned here previously) called Divergent Country Views of Base Erosion and Profit-Shifting. Details available here. I'll be moderating and commenting on a panel that meets from 8:15(!) to 9:45 am, discussing the European Commission's state aid cases.
At this session, I will not be just reprising my recent Tax Notes paper on the topic, which is available here. For example, I will focus much more than I did in that paper on the relevance of “source” issues to the analysis.
Second, on Wednesday, November 2, from 6 to 8:30 pm, I'll be participating in a session sponsored by the New York City Bar Association (and held at the NYC Bar building, 42 West 44th Street), entitled Beyond Labels: Exploring the Revised Scope of the Final and Temporary Section 385 Debt-Equity Recharacterization Regulations. Details are available here.
I'll be speaking towards the middle (or later) of this event. As we will already, by then, have had extensive coverage of the nuts-and-bolts aspects of the topic, I'll offer a more big-picture perspective on three issues: the use of regulations instead of legislation to address corporate inversions, issues around Treasury regulatory discretion and court challenges to regs generally, and the prospects for international tax reform that includes addressing earnings-stripping via the use of interest deductions.