Tax Lunch Forum – Speakers: Carol Dunahoo and Mary Bennett of Baker & McKenzie

Date: 9/15/04

To: NFTC Tax Committee

Re: September 15th Tax Lunch Forum

The next NFTC Tax Luncheon Forum to discuss current international tax developments will be held on Wednesday, September 15th at 12:00 p.m. ET, at ChevronTexaco”s Offices, 1401 Eye Street, NW, Suite 1200, Washington, DC.‚Äînote the location change (due to construction in the building adjacent to the NFTC).
I am pleased that Carol Dunahoo and Mary Bennett of Baker & McKenzie will join us to discuss the recently released OECD document, Attribution of Profits to a Permanent Establishment: Revised discussion draft for public comment:,2340,en_2649_37427_33640797_1_1_1_37427,00.html.  Carol and Mary have also provided a redlined version of the document at (–Redline.doc), prepared by their colleague Matt Sullivan, which reflects the changes from the 2001 OECD draft.  This new draft makes a number of changes and adds important new material regarding the attribution of assets, risks, and capital under its functional and factual analysis; the treatment of capital assets, intangible assets, and internal services; the treatment of dependent agent PEs; and other issues.  Please plan to attend and join in.  The comments period deadline is September 28th.
For those attending the meeting, lunch will be provided for $35, payable by check or credit card. Please register in advance so that we can make the necessary lunch arrangements or provide the conference call-in number to you.  For those who are outside the Washington Metropolitan area who cannot attend in person, a call-in number will be provided to you, however, you must return the attached response form to before the call-in information will be sent to you.  Please complete the attached response form to attend or participate in the conference call and return it by Monday, September 13th (note that no refunds will be made after Monday).

Note to conference call in participants: To give our speaker time to eat lunch, the discussion usually starts at approximately 12:15pm; (i.e., the call-in number will activate at 12:15pm).  Also, please put your phones on mute unless you are speaking and DO NOT PUT YOUR PHONE ON HOLD AT ANY TIME during the call.
2004 NFTC Tax Committee Calendar
The calendar is also available at the NFTC website,

• October 13 (Wednesday) Tax Lunch Forum

‚Ä¢ November 16-17 (Tuesday-Wednesday) Fall Tax Committee Meeting‚ÄîWashington, DC  (Note date change)

I look forward to seeing you.

Judy Scarabello
Vice President for Tax Policy
202 887 0278, extension 105