The Northwestern Graduate Tax Program hosts a symposium today on International Tax Reform in a Reset Economy:

Business people, tax practitioners, and legal academics generally agree that the United States international tax regime is broken. Criticisms abound that the system is overly complicated, disadvantageous to American businesses competing in a global economy, and frequently subject to manipulation and abuse.Over the recent past, individuals and groups across the political spectrum have proposed numerous reforms to address these problems, some of which seek simply to modify current requirements while others jettison the current system in favor of dramatic alternatives.

The staggering economic recession of the last 18 months has significantly compounded the stakes in the ongoing debate over international tax reform.The federal government incurred an enormous financial burden in rescuing the financial system from near collapse and in stimulating the economy to avoid another Great Depression. In doing so, the federal deficits for 2009 and 2010 as a percentage of GDP are at levels not seen since World War II. Greater government revenues are desperately needed, and international business activities are being examined as a source for these revenues.

This symposium brings together government officials, business representatives, tax practitioners, and academics to examine problems with the current international tax system and the reforms that have been proposed, all in light of the current economic crisis.Importantly, individuals with real-world experience in both the private and public sectors will discuss the political and institutional forces that will affect the substantive results of any reform efforts that are sure to be undertaken.

Panel 1 – “What is Broken with the Current System”
Specific reform proposals can only be considered after identifying the underlying problems with the current international tax system. Panelists will discuss the range of problems under the tax law that confront businesses and their advisors when engaged in international transactions.

• Academic: Robert J. Peroni (University of Texas)
• Business: William J. Sample (Microsoft), Robin D. Beran (Caterpillar)
• Practitioner: Robert H. Dilworth (McDermott Will & Emery), Steven M. Surdell (E&Y)

Panel 2 – “Incremental versus Fundamental Reform”
Recent reform proposals have ranged from the modification of existing rules to the complete overhaul of the current system and its replacement with one or more alternatives. Panelists will discuss recent reform proposals, how the current system might be salvaged, and whether proposed alternatives—in practice, as well as in theory—are preferable to the current system as reformed.

• Academic: Lawrence Lokken (University of Florida), William B. Barker (Penn State)
• Business: Janice L. Lucchesi (Akzo Nobel), Tobin Treichel (United Technologies)
• Practitioner: Lowell D. Yoder (McDermott Will & Emery)

Panel 3 – “The Potential Contours of International Tax Reform”
Once the process to reform the international tax system is initiated, certain agreed upon principles are needed to ensure that the results of that process achieve the desired policy goals. Panelists will discuss the principles that might be adopted and where trade-offs between conflicting principles can be made.

• Academic: Edward D. Kleinbard (University of Southern California)
• Government: Stephen E. Shay (Deputy Assistant Secretary for International Tax Affairs)
• Business: John M. Samuels (General Electric)
• Practitioner: Barbara M. Angus (E&Y)

Panel 4 – “The Political Reality of Reform”
Real reform of the international tax system can only take place within the political process which is, in practice, unwieldy and unpredictable. Based on past examples and their personal experiences, panelists will discuss the political forces that will influence the reform process and the institutional context in which that reform will occur.

• Academic: Elizabeth Garrett (University of Southern California)
• Business: David Lewis (Eli Lilly)
• Practitioner: Eric Solomon (E&Y), Pamela F. Olson (Skadden), Leslie Samuels (Cleary Gottleib), Mark A. Weinberger (E&Y)