PROVISIONAL PROGRAM

(Subject to change/augmentation)

APRIL 5, 2005

Taxation of U.S. Shipping Companies Under Subpart F :A Brief History of Taxation of U.S. Shipping Companies
Joe Gulant, Esq., Partner, Blank Rome LLP

The Lesson of History: Look what happened to the U.S.-controlled tanker fleet
William O. Gray, Gray Maritime Corp.

Economic and Policy Factors Behind the Recent Tax Changes
Arnold I. Havens, General Counsel, U.S. Department of the Treasury

Overview of Changes to Subpart F Included in the American Jobs Creation Act of 2004
Joe Gulant, Esq., Partner, Blank Rome LLP

Questions and Discussion

Luncheon

Practical Application and Effect of New Subpart F Rules: Opportunities for U.S. Shipping Companies
Brett Esber, Esq., Partner, Blank Rome LLP

Choice of flag and corporate location
Clay Maitland, Managing Partner, International Registries

Tax Issues Related to Establishment and Operation of Offshore Company
Joe Gulant, Esq., Partner, Blank Rome LLP
Cory Jacobs, Esq., Associate, Blank Rome LLP

Will U.S. shipping companies be on an equal footing with non-U.S. shipping companies?
David A. Lifson, CPA, Partner, Hays & Company LLP (Globally: Moore Stephens Hays LLP)

Opportunities for U.S. Investors, Investment Outlook
Andrian R. Dacy, JP Morgan

Other Changes to Taxation of U.S. Shipping Companies Included in the American Jobs Creation Act of 2004
James K. Wall, Principal, Ernst & Young International Tax Services

Questions and Discussion

Cocktail Reception - Sponsored by Blank Rome LLP



APRIL 6, 2005

Shipping Taxation: A European Perspective
Werner Heyvaert, Head of Tax Law Practice, Stibbe, Brussels

The Alternative Tonnage Tax What is the tonnage tax?
Joanne Song, PriceWaterhouseCoopers
Joe Gulant, Esq., Partner, Blank Rome LLP

Why is the tonnage tax good for U.S.-flag shipping companies?
Joe Cox, President, Chamber of Shipping of America

When can a U.S.-flag shipowner opt for the tonnage tax, and when does it make sense?
James K. Wall, Principal, Ernst & Young International Tax Services

U.S. Income Taxation of Foreign Shipping Companies
Cory Jacobs, Associate, Blank Rome, LLP

Questions and Discussion

Subject to change or augmentation.

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