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Multi-Jurisdictional Taxation of Electronic Commerce

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Date: Thu, 20 Feb 1997 16:58:48 -0500 From: Lara Becker

The International Tax Program Harvard University

International Tax Program and the Tax Law Society 1997 Spring Symposium on

MULTI-JURISDICTIONAL TAXATION OF ELECTRONIC COMMERCE

Saturday, April 5, Cambridge, Massachusetts,U.S.A.

The Symposium:

Billions of dollars of valuable goods and services are sold, exchanged or transmitted electronically. The amount of such commercial activity is expected to grow exponentially in the future. The appropriate taxation of this sector is one of the most significant new tax issues of our day. The International Tax Program and the Society for Law and Tax Policy of Harvard Law School are sponsoring a symposium that will bring together the leading policy makers, academics and practitioners in this field in an effort to help derive uniform tax rules in this challenging dimension of domestic and international taxation.

This symposium will consider a wide range of issues, including:

**Differences in determining the electronic commerce income tax base. Should source or residence rules be used, or should some form of formulary apportionment be applied?

**Problems in imposing retail sales taxes on electronic sales. Should traditional nexus rules apply?

**Problems in determining the value added by electronic commercial inputs. Should a tax be determined based on the 'bits' of information? If so, should each 'bit' be valued the same?

**Problems involving the harmonization of tax rules. International and sub-national aspects of this problem will be considered. OECD efforts in this area will be contrasted with proposed uniform state legislation in the US.

**Throughout the symposium the impact that these tax decisions will have on cross-border investment decisions will be a primary concern.

The Goals of the ITP:

The International Tax Program continues to sponsor symposiums on topics of critical concern to government and private sector tax practitioners at Harvard University. It is the belief of the Program that such discussions will lead to advances in tax policy, administration and compliance on a global basis. THE MULTI-JURISDICTIONAL TAXATION OF ELECTRONIC COMMERCE presents such a challenge. Basic Income tax objectives such as efficiency and equality of treatment are made more difficult to achieve if the rules of the game are left to develop on an ad hoc basis. Through this forum the International Tax Program hopes to facilitate a meaningful interaction among policy makers around the core issues of taxation and the internet.

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Schedule:

Saturday, April 5, 1997

7:30 - 8:30: Coffee and Registration

8:30 - 9:00: Keynote Speaker, Mr. Jeffrey Owens, Chief, Fiscal Affairs Division: OECD (Paris)

9:00 - 11:30:INTERNATIONAL PANEL:

Moderator: Professor Diane Ring, Harvard Law School

Speakers: Mr. Bruce Cohen, Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury

Mr. Alan S. S. Ow, Senior Deputy Commissioner, Inland Revenue Authority, Singapore

Mr. Nicasio del Castillo, Partner, Coopers & Lybrand

Professor Luc Soete, Maastricht Economic Research Institute on Innovation and Technology, University of Maastricht, the Netherlands

Mr. Arthur Cordell, Industry Canada, Special Advisor for Long Range Planning and Analysis

11:30 - 12:30: Catered Lunch

12:30 - 3:00: STATE PANEL

Moderator: Professor Reuven Avi-Yonah, Harvard Law School

Speakers: Ms. Deborah Bierbaum, Deputy Commissioner, Office of Tax Policy, Department of Taxation, New York

Ms. Linda Lettera, General Counsel, Department of Revenue, Florida

Mr. Wade Anderson, Director of Tax Policy, Comptroller of Public Accounts, Texas

Mr. Dean F. Andal, Member, State Board of Equalization, Second District, California

Mr. Walter Hellerstein, Attorney, Southerland, Asbill & Brennan

3:00 - 3:30: Coffee

3:30 - 6:00: INDUSTRY PANEL

Moderator: Professor Richard Pomp, University of Connecticut Law School

Speakers: Ms. Jeanne Goulet, Director of Tax, IBM Credit, IBM

Ms. Allyn Yamanouchi, Vice President and Global Technology Tax Counsel, CITIBANK

Mr. James Eads, Jr., and Mr. Paul Nolan, Legal Division, AT&T

Mr. Bruce Reid, Director of State and Local Tax, MICROSOFT

Ms. Ellen Fishbein, Assistant General Counsel, AMERICA ONLINE

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Registration and Fees:

The fee for this program is $500.00. An academic or government employee discount is available. That fee is $200.00. To register for the symposium please fill out and return the form below, with a check or money order made payable to Harvard University, to:

Multi-Jurisdictional Taxation of Electronic Commerce Symposium Attn: Lara Becker 1563 Massachusetts Avenue Pound Hall, Room 400 Cambridge, MA 02138 Lbecker@law.harvard.edu

Fax: 617-495-0423 Tel: 617-495-4406

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Registration Form:

1997 Spring Symposium on Multi-Jurisdictional Taxation of Electronic Commerce, Saturday, April 5, 1997.

Mr./Ms.

Name (First or Given Name)

(Surname or Family Name)

Email Address:

Title:

Organization:

Home Address/Work Address:

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Fax Number:

I am Paying by:

Check:

Money Order: ```

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