The 29th Annual Institute on Current Issues in International Taxation

Transcription

1 The 29th Annual Institute on Current Issues in International Taxation Arnold, Joan C. Partner Pepper Hamilton LLP Joan Arnold is a partner with Pepper Hamilton LLP, resident in the Philadelphia office, where she is the chair of the Tax Practice Group, and focuses her practice on federal and international income tax. Joan has more than 35 years of significant experience in domestic and cross border M&A, and corporate international tax counseling, including substantial tax experience in the private equity arena. Joan is the president of the American College of Tax Counsel, vice chair of the Tax Section of the American Bar Association, vice president and a member of the executive committee of the U.S. Branch of the International Fiscal Association, and on the executive committee of the George Washington/IRS Annual International Tax Institute. Joan was highly ranked (Tier1) by Chambers USA: America s Leading Lawyers for Business in tax law for 2016 and is listed in The Best Lawyers in America and was named the Philadelphia Best Lawyers Tax Lawyer of the Year for Joan is also included in the Pennsylvania Super Lawyers list and also is listed in The International Who s Who of Corporate Tax Lawyers, The International Who s Who of Business Lawyers, Who s Who Legal International Corporate Tax. Before entering private practice, Joan was vice president, associate general tax counsel for Citicorp, a full-time faculty member at Rutgers University School of Law Camden, and a consultant in international tax to KPMG in its national office. She holds a B.A. (mathematics) from Wagner College, a J.D. from Villanova University School of Law, and an LL.M. (taxation) from New York University School of Law. Bello, Christopher Chief, Branch 6, Associate Chief Counsel (International) Internal Revenue Service Chris Bello is the branch chief for Branch 6 of the Office of the Associate Chief Counsel (International), IRS. Branch 6 is responsible for international transfer pricing as well as a number of other practice areas. Chris was a drafter and reviewer of the proposed, temporary, and final cost sharing regulations and was the reviewer of the final services regulations. He has been a member of the U.S. delegation to OECD Working Party No. 6 on the Taxation of

2 Multinational Enterprises for more than eight years, working on matters including the revision of Chapters I through III of the Transfer Pricing Guidelines and the addition of Chapter IX, the project on intangibles, and the base erosion and profit shifting project. Chris obtained an undergraduate degree from Princeton University, a law degree from the University of Virginia School of Law, and an LL.M. in taxation from the University of Florida School of Law Graduate Tax Program. He is a member of the Florida Bar. Bennett, Mary C. Partner Baker & McKenzie LLP Mary Bennett is a tax partner in Baker & McKenzie s Washington, DC office, where she advises both U.S. and foreign-based companies on tax policy issues and assists them with international tax planning and controversy matters. She is the Chair of the Firm s Global Tax Policy Group. Mary has more than 35 years of international tax experience, including having served from 2005 to 2011 as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the OECD s Centre for Tax Policy & Administration in Paris and earlier in her career as the Deputy International Tax Counsel of the U.S. Treasury Department. She has been recognized as one of America s leading tax lawyers by Chambers USA, The International Who s Who of Corporate Tax Lawyers, and Euromoney s Guide to Women in Business Law and Guide to the World s Leading Tax Advisers. She is a graduate of Harvard University and Columbia Law School and holds a master of laws degree in taxation from Boston University Law School. Brown, Karen B. Donald Phillip Rothschild Research Professor of Law The George Washington University Karen B. Brown is the Donald Phillip Rothschild Research Professor of Law at the George Washington University Law School, where she teaches courses in Federal Income Taxation, Corporate Taxation, and International Taxation. Before joining the faculty at George Washington University, Professor Brown was Professor of Law and Associate Dean for Academic Affairs at University of Minnesota Law School and Professor of Law at Brooklyn Law School. She was appointed the Julius E. Davis Professor of Law for at University of Minnesota. Professor Brown is co-author of an international tax transactions treatise and co-editor of books on taxation reform, comparative law, and economic efficiency and tax law. She is editor of a comparative book on regulation of tax avoidance

3 and co-editor of the General Reports for the 18 th Congress of the International Academy for Comparative Law. She has published numerous articles and book chapters on federal income, corporate, international taxation. She is a member of the American Law Institute, International Academy for Comparative Law, and the International Fiscal Association. Brown, Patrick J. Tax Director GE Power & Water Patrick Brown is GE s Vice President, Tax for GE Power, Energy Connections, and Renewables and is GE s director for Tax Policy. Prior to joining GE Power, Pat was a senior international tax counsel for GE corporate and GE Capital, and was a principal technical advisor to the tax director of GE on tax policy matters. Pat joined GE in 2002 from the US Treasury Department, where he served as attorney-advisor and associate international tax counsel from During his time at Treasury, Pat focused primarily on international tax analysis, negotiation of tax treaties, and representing the US government at meetings of the OECD on various tax issues. Prior to joining the Treasury Department, Pat was an associate at Sullivan & Cromwell in New York. Pat received a B.S. in Mechanical Engineering, with highest distinction, from the University of Virginia and a J.D. from Georgetown University, magna cum laude, in Caballero, Michael J. Partner Covington & Burling LLP Michael J. Caballero is a tax partner at Covington & Burling LLP in the firm s Washington D.C. office. Prior to joining Covington, he spent two and a half years in the Treasury Department s Office of Tax Policy, from February 2010 to August 2012, first as Deputy International Tax Counsel, and then as International Tax Counsel. He also spent over five and a half years in the Office of Tax Policy from 1999 through 2004, as an Attorney-Advisor and Associate International Tax Counsel. In between his two stints at the Treasury, he was an international tax partner in the Washington D.C. office of two global law firms. Mr. Caballero received a B.S. in Mathematics (with a concentration in Computer Science), magna cum laude, from the University of Notre Dame, a J.D., cum laude, from the Georgetown University Law Center, and an LL.M. in Taxation from the New York University Law School.

4 Crispino, Paul J. Senior Director, International Tax United Technologies Corporation Paul J. Crispino is a Senior Director, International Tax, at United Technologies Corporation (UTC). Paul also is the current chair of the Foreign Activities of U.S. Taxpayers Committee of the American Bar Association. Prior to joining UTC, Paul was an international tax principal with Deloitte Tax s Washington National practice and an Associate Tax Legislative Counsel with the U.S. Treasury s Office of Tax Policy. Paul is a frequent speaker and commentator on U.S. international tax matters. Culbertson, Robert E. Partner Covington & Burling LLP Rob Culbertson is a tax partner at Covington & Burling LLP, where his practice focuses on international tax planning and controversy resolution. He represents some of the largest US- and non-us- based multinationals in connection with their structural and transactional tax planning. He also represents clients before the IRS, the U.S. Treasury, and Congress, regarding audit controversies, rulings, regulations, and legislative issues. A graduate of Yale University and Harvard Law School, Mr. Culbertson served 13 years in the government, including a four-year stint as the Associate Chief Counsel (International) at the IRS from 1991 to During his tenure as Associate Chief Counsel, Mr. Culbertson participated in many significant developments in US international taxation, including the revision of the US transfer pricing regulations, the parallel development of new OECD guidelines, and the development of regulations relating to foreign tax credits, subpart F rules, outbound transfers, conduits, and other international tax issues. Earlier in his career, he was the principal author of regulations under FIRPTA and Section 367, and he served on the staff of the Joint Committee on Taxation during the development of the Tax Reform Act of His recent listings include Chambers Global, Chambers USA, Legal 500 US, Best Lawyers in America, Washington DC Superlawyers, and Who s Who Legal. Dicker, Eli J. Executive Director Tax Executives Institute Eli J. Dicker is Chief Tax Counsel to the Tax Executives Institute. He is the lead technical tax adviser overseeing Institute advocacy efforts and initiatives including those related to pending or proposed tax legislation and regulations, treaties, administrative and judicial pronouncements. He leads a legal team in

5 the development of position papers, testimony, comment letters and amicus briefs. In addition, he serves as liaison to federal and state administrative and regulatory authorities including the U.S. Treasury and the Internal Revenue Service. Prior to joining TEI, Eli was employed at Capital One Financial Corporation, where he led the Tax Accounting and Reporting function, overseeing federal and state tax accounting, reporting and compliance. Eli s prior experience also includes service as a tax principal with KPMG LLP and as an attorney-adviser and trial attorney in the Office of the Associate Chief Counsel (International) and Miami District Counsel office of the Internal Revenue Service. Eli is also an Adjunct Professor of Law at Georgetown University Law Center where he teaches a Cross-Border Tax Controversy Workshop. Eli holds BA, magna cum laude, and MA degrees (political science) from Queens College, City University of New York, a JD from Northeastern University School of Law and an LLM (Taxation) from New York University School of Law. Dorfman, Jeffrey L. Managing Director PricewaterhouseCoopers LLP Jeffrey Dorfman is a managing director in the International Tax Services group at PwC where he provides advice on foreign currency and other financial products issues. Prior to joining PWC, Jeff was the Chief of Branch 5 in the Office of the Associate Chief Counsel (International) for over twenty years. Branch 5 has jurisdiction over foreign currency issues, cross border financial products issues including subpart F issues relating to foreign currency, foreign banking issues including , treaty issues such as the authorized OECD approach under Article 7 and trade or business/eci issues regarding inbound investment vehicles. Jeff is also the principal author of the section 988 regulations, the 2006 proposed section 987 regulations and the regulations regarding transition to the euro, among other things. Erwin, Mark Chief, Branch 5, Associate Chief Counsel (International) Internal Revenue Service Mark Erwin is the Branch Chief in Branch 5 of the I.R.S. Office of Associate Chief Counsel (International). He specializes in the taxation of foreign financial institutions, foreign currency transactions, and cross-border financial products. Prior to joining Chief Counsel in 2006, Mr. Erwin spent several years practicing tax law at firms in Washington D.C., including Skadden and Latham & Watkins. Mr. Erwin has a J.D. from New York University (2002), a Ph.D. in

6 English literature from Princeton University (1998) and a B.A. from Trinity University (1992). Farmer, F. Scott Partner Morgan, Lewis & Bockius LLP Scott Farmer advises clients on all aspects of international tax planning and controversy with the Internal Revenue Service. His clients include US firms engaged in non-us business activities as well as non-us firms operating within the United States. Scott frequently lectures at the Tax Executives Institute and other tax forums. He also writes on international tax topics, including Tax Year Splitters It's Accrual Method Annual Accounting, 133 Tax Notes 1491 (Dec 19, 2011). Scott is named one of the country s leading practitioners in taxation by Chambers USA, one of the world s leading practitioners in international tax by Chambers Global, a leader in mergers and acquisitions and cross-border structuring by International Tax Review s World Tax, and one of the Best Lawyers in America. Prior to joining Morgan Lewis, Scott was a partner in the corporate practice of another international law firm. He is a member of the American Bar Association s Tax Section s Committee on Foreign Activities of US Taxpayers. Femia, Rocco V. Partner Miller & Chevalier Chartered Rocco V. Femia is a member of Miller & Chevalier Chartered. Mr. Femia s practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies involving U.S. international tax rules, transfer pricing, and U.S. tax treaties. Mr. Femia routinely advises businesses on Advance Pricing Agreements and mutual agreements under tax treaties. Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy. While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters. Mr. Femia writes and speaks regularly on a variety of international tax and transfer pricing issues, and is a former Adjunct Professor at the Georgetown University Law Center. Mr. Femia graduated, magna cum laude, from Georgetown University Law Center in He received his B.A. in Economics from Duke University in 1991.

7 Fowler, Tadd A. Vice-President Global Tax The Proctor & Gamble Company Tadd joined The Procter & Gamble Company in He is Vice President Tax Operations and is located in Cincinnati. Prior to joining P&G, he was an international tax partner with PricewaterhouseCoopers, and spent time with General Electric Company early in his career. Tadd is a member of the AICPA and State CPA Societies in Kansas and Missouri. Tadd is also a frequent speaker at TEI and other tax and international organizations. Gall, Phillip Principal Ernst & Young LLP Phillip Gall is a Principal in the Partnership Transaction Planning & Economics Group in Ernst & Young LLP s National Tax Department and is located in New York. He focuses on the taxation of partnerships, joint ventures, and limited liability companies. Phillip has significant experience in the formation, operation, and unwinding of these types of entities for large multinationals and for investment funds in both the international and domestic context. Phillip also has experience representing clients in connection with federal and state tax controversies involving partnership tax matters. Phillip is an Adjunct Professor at New York University School of Law, where he has taught partnership tax courses for a number of years, and is a member of the Executive Committee of the New York State Bar Association Tax Section. He is also a frequent speaker on partnership tax matters at conferences throughout the country. Phillip has published the following articles: Phantom Tax Regulations: The Curse of Spurned Delegations (Tax Lawyer, Winter 2003), Partnership Distributions of Marketable Securities (Tax Notes, Nov. 12, 2007), and most recently, The Mysterious Case of Disappearing Debt in Partnership Transactions (Taxes, March 2012). Prior to joining Ernst & Young LLP, Phillip was a Co-Managing Principal for the national partnership tax practice of another Big 4 accounting firm. From 1994 until 2009, Phillip practiced law and became the co-head of the law firm s tax practice. Phillip has a B.S.B.A., summa cum laude, from Washington University and a J.D., cum laude, and LL.M. (Tax) from New York University School of Law.

8 Galler, Linda Professor of Law Hofstra University School of Law Linda Galler is Professor of Law at the Maurice A. Deane School of Law at Hofstra University. She is the lead author of Regulation of Tax Practice, published by LexisNexis as part of its Graduate Tax Series, and is a former chair of the ABA Tax Section s Standards of the Tax Practice Committee. Professor Galler also is Senior Tax Counsel to the New York City law firm Curtis, Mallet-Prevost, Colt & Mosle, where she consults in the areas of international taxation, corporate taxation, administrative practice and court procedure. Harris, Mark D. Senior Tax Counsel The Coca-Cola Company Mark Harris is currently a Senior Tax Counsel with The Coca-Cola Company. Prior to joining The Coca-Cola Company, Mark spent a number of years with Ernst & Young in their Washington, DC national tax office, after starting his career in the Passthroughs and International divisions at the Internal Revenue Service s Office of Chief Counsel. Mark has held many positions in the Tax Section of the American Bar Association, including two years serving as the Chair of the Foreign Activities of US Taxpayers (FAUST) Committee. Harter, L.G. Chip Principal, WNTP PricewaterhouseCoopers LLP L.G. "Chip" Harter is a principal in the PricewaterhouseCoopers LLP Washington National Tax Practice. His practice focuses on advising multinational corporations on international tax planning and on tax issues arising with respect to financing transactions and financial instruments. Mr. Harter joined PricewaterhouseCoopers in 1999 after having practiced tax law with Baker & McKenzie for 18 years. Mr. Harter is a past Chair of the Financial Transactions Committee of the American Bar Association Section of Taxation. His recent publications include: Code Sec. 385 Proposed Regulations Would Vitiate Internal Cash Management Operations, Vol. 42, No. 4 International Tax Journal, p. 5 (July-August 2016) (with Jared Hermann and Aaron Junge); and "The Devil is in the Details: Problems, Solutions and Policy Recommendations with Respect to Currency Translation, Transactions and Hedging," Vol. 89, No. 3 Taxes, p. 199 (March 2011) (with John D. McDonald, Ira G. Kawaller, and Jeffry P. Maydew). He is co-author of BNA Portfolio 187, Taxation of Non-Equity Derivatives, and BNA Portfolio 189, U.S. Taxation of Notional Principal Contracts.

9 Mr. Harter earned a JD from the University of Chicago Law School in 1980, where he was Comments and Articles Editor of the University of Chicago Law Review, and he graduated magna cum laude from Harvard College in Following law school, Mr. Harter clerked for the Honorable Thomas R. McMillen, United States District Judge for the Northern District of Illinois. Hemel, Daniel Assistant Professor of Law University of Chicago Law School Daniel Hemel is an assistant professor at the University of Chicago Law School, where he teaches tax, administrative law, and torts. Prior to his appointment, he was a law clerk to Associate Justice Elena Kagan on the U.S. Supreme Court. He also clerked for Judge Michael Boudin on the U.S. Court of Appeals for the First Circuit and Judge Sri Srinivasan on the U.S. Court of Appeals for the District of Columbia Circuit, and served as visiting counsel at the Joint Committee on Taxation. Daniel graduated summa cum laude from Harvard College and received an M.Phil with distinction from Oxford University, where he was a Marshall Scholar. He then earned his J.D. from Yale Law School, where he was editorin-chief of the Yale Law Journal. His articles have appeared or are forthcoming in the Cornell Law Review, Minnesota Law Review, Tax Law Review, Tax Notes, Texas Law Review, and University of Chicago Law Review. He blogs at WhateverSourceDerived.com. Hughes, John Acting Director Advance Pricing and Mutual Agreement Program Internal Revenue Service John Hughes presently serves as Acting Director, APMA. John joined the IRS in September Prior to assuming his current assignment, John was Senior International Advisor to the Director, Treaty and Transfer Pricing Operations. John has also been a Senior Manager in APMA. Before joining the IRS, John worked at the Washington offices of Mayer Brown LLP. John received a JD and an MA (Applied Economics) from the University of Michigan in Huynh, Quyen Associate International Tax Counsel U.S. Department of Treasury Quyen Huynh is an associate international tax counsel in the Office of the International Tax Counsel (ITC) of the U.S. Treasury Department. At Treasury,

10 she works on a variety of U.S. international tax and income tax treaty matters, with a focus on income tax treaties, withholding and information reporting, FATCA and intergovernmental agreements to implement FATCA. She is also a delegate to the OECD working parties that focuses OECD s work on tax treaty matters and on exchange of information, including the OECD s Common Reporting Standard. Prior to joining the ITC, she was a Senior Counsel in the Office of Associate Chief Counsel (International), where she worked on a broad range of international tax matters, including interpretative income tax treaty issues, foreign trust reporting, cross-border individual taxation matters, and withholding and information reporting. She has worked extensively with the IRS on the development of a variety of technical implementation projects related to FATCA, and previously detailed to work for the Deputy Commissioner (International). She has also taught courses as an adjunct professor of law at Georgetown University Law Center. Ms. Huynh has a B.A. from Mount Holyoke College, a J.D. from the University of San Diego School of Law, and an LL.M. in Taxation from Georgetown University Law Center. Jenn, Brian H. Attorney Advisor U.S. Department of Treasury Mr. Jenn joined the Office of the International Tax Counsel in the Treasury Department's Office of Tax Policy in January At Treasury, he focuses on a wide range of international tax legal and policy issues, developing regulations and other guidance related to subpart F, foreign currency issues, transfer pricing, digital economy and cloud issues, and cross-border reorganizations. He is a U.S. Treasury delegate to OECD s Working Party 6 on Transfer Pricing, which has responsibility for the development of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and to the OECD s Task Force on the Digital Economy. Mr. Jenn earned his B.A. and M.A. (Economics) at Northwestern University and his J.D. at Yale Law School. Prior to joining Treasury, Mr. Jenn worked on international tax issues at a law firm in Washington, DC, and served at the Council of Economic Advisers ( ) and in the U.S. Senate on the Chairman s staff of the Joint Economic Committee ( ).

11 Kane, Thomas J. Division Counsel, LB&I, Office of Chief Counsel Internal Revenue Service Tom Kane is currently the Division Counsel for the Office of Large Business & International Division Counsel function within the IRS Office of Chief Counsel in Washington, D.C. Within the IRS, the LB&I Division handles large business and international tax issues. As LB&I Division Counsel, Tom oversees the tax litigation conducted by the IRS in the U.S. Tax Court and legal advice provided to the IRS by over 300 LB&I attorneys and paralegals located throughout the country. Tom previously served as the Division Counsel with the Tax Exempt & Government Entities Division Counsel function. Tom received his J.D. degree (with distinction) from The John Marshall Law School, where he was a member of the law review staff, and has advanced degrees in taxation, international legal studies, and public health. Kleinberg, Rachel D. Partner Davis Polk and Wardwell LLP Ms. Kleinberg is a partner in Davis Polk s Tax Department, practicing in the Menlo Park office. Her practice focuses on advice to corporate and private equity fund clients on mergers and acquisitions, joint ventures, spinoffs and reorganizations, as well as cross-border restructurings. She also has significant experience in the areas of corporate finance and derivatives. Konza, Mark Deputy Commissioner, International Australian Taxation Office Mark is the Deputy Commissioner responsible for international taxation in the ATO. He leads the development of ATO strategy in response to the base erosion and profit shifting, offshore tax evasion and foreign investment risks. He represents Australia at various OECD forums, particularly the Taskforce of the Digital Economy. Koskinen, John Commissioner Internal Revenue Service John Koskinen was nominated by President Obama to be the 48th Commissioner of the IRS and was confirmed by the Senate on December 20, 2013, for a term thatexpires in November, Previously, Mr. Koskinen served as Non-Executive Chairman of the Board of

12 Freddie Mac from September, 2008, until February, 2012, except for the six months he served as interim CEO, COO and CFO during From he was President of the United States Soccer Foundation, the charitable arm of soccer in the United States. Mr. Koskinen earlier served as Deputy Mayor and City Administrator for the District of Columbia from September 2000 to September of 2003, responsible for the operation of all city departments. Prior to his service as Deputy Mayor, Mr. Koskinen occupied several positions with the United States Government, including service from 1994 to 1997 as Deputy Director for Management of the Office of Management and Budget, where, among other duties, he coordinated the work of the Chief Financial Officers, Chief Information Officers and Inspectors General of all Federal agencies. He also ran the two government shutdowns in From 1998 to 2000, he served as Assistant to the President and Chaired the President s Council on Year 2000 Conversion, coordinating the country s transition into the new century. Prior to his most recent service with the U.S. Government, Mr. Koskinen joined the Palmieri Company, which specialized in turnaround management, as Vice President and later served as President and CEO from 1979 to 1993, participating in the reorganization of the Penn Central Transportation Company, Levitt and Sons, and Mutual Benefit, at the time the largest failed life insurance company in history. Earlier in his career, Mr. Koskinen worked on the staff of the National Advisory Commission on Civil Disorders (the "Kerner Commission"), represented New York City and Mayor John Lindsey in Washington, and served as Administrative Assistant for four years for Senator Abraham Ribicoff of Connecticut. Mr. Koskinen graduated with a JD, Cum Laude, from Yale University School of Law and a BA in Physics, Magna Cum Laude, from Duke University. He studied International Law for one year at Cambridge University in England. Mr. Koskinen was a trustee of Duke University for 12 years, serving as Chairman of the Board for three years. He served on the Board of the AES Corporation from and the Board of American Capital, Ltd. from Kurihara, Takeshi Deputy Commissioner for International Affairs National Tax Agency Takeshi Kurihara is Deputy Commissioner for International Affairs, National Tax Agency, Japan since June this year.

13 He joined Japan s Ministry of Finance in 1986 and since assumed a wide range of positions within the Ministry. For the past decade at the positions of various Directors at International Bureau of JMOF, he contributed to formulating JMOF s international financial policies towards US, Europe and Asia, and represented Japan s delegations in a number of international fora including those under the ASEAN+3 Finance Minister s process (CMIM Task Force, ABMI meeting), the APEC Finance Ministers process (Senior Finance Officials Meeting), and the Paris Club. He also supervised JICA, JBIC and participated in policy making of Japan s ODA and non-oda loans. During his secondement to the Financial Service Agency, he worked for issues of income taxation and international taxation in the financial sectors. Prior to the current position, he was Chief Financial Officer and Member of the Board of the Innovation Network Corporation of Japan (INCJ), government sponsored Venture Capital and Private Equity Fund Company and the member of its Investment and Monitoring Committees. Mr. Kurihara graduated the University of Tokyo in He was lecturers at graduate schools (Saitama University, University of Tokyo, etc.) and published a book titled French economy under the Euro (in Japanese in 2005). Lassman, Bruce Vice-President International Tax IBM Corporation Bruce joined IBM in 2007 and is in charge of global tax planning. In this role, Bruce develops global tax strategies which involve tax minimization as well as optimizing the mobilization of cash around the globe. Prior to joining IBM, Bruce spent 9 years as Director of International Tax at FordMotor Company in Dearborn, Michigan where he had similar responsibilities. Bruce is a seasoned international tax specialist as he also has experience working as an international tax partner at Ernst & Young in Detroit, Chicago, London and New York. Bruce has presented at the George Washington University annual tax conference, KPMG/NYU annual lecture series as well as International Fiscal Association programs. He has been quoted as an international tax expert in the Wall Street Journal and London Financial Times and has appeared on CNN. Bruce has a B.S. and M.S. in Accounting from the Wharton School and a J.D. from Cornell Law School.

14 Leska, Timothy J. Partner Pepper Hamilton LLP Timothy J. Leska is a partner with Pepper Hamilton LLP, resident in the Philadelphia office. Mr. Leska focuses his practice on the tax aspects of complex mergers and acquisitions, both domestic and cross-border, with a specialization in transactions involving the formation, acquisition, operation and dispositions of partnerships and LLCs. Prior to joining Pepper, Mr. Leska was an attorney in the Office of Chief Counsel (Passthroughs and Special Industries) for the Internal Revenue Service in Washington, DC. Lew, Mae Special Counsel, Associate Chief Counsel (International) Internal Revenue Service Mae J. Lew is currently serving as a Special Counsel to the Deputies Associate Chief Counsel (International) in the Office of Chief Counsel, Internal Revenue Service. Ms. Lew is also one of the U.S. delegates at the Organization for Economic Cooperation and Development (OECD), focusing on global transparency and exchange of information. Prior to joining International, Ms. Lew was detailed to Main Treasury, where she handled a number of high profile matters for the General Counsel. Before coming to Washington, D.C., Ms. Lew was a senior attorney in Area Counsel s office in Boston, Massachusetts, where she litigated numerous cases in Tax Court and served as a Special Assistant United States Attorney for the Department of Justice in Bankruptcy Court. Ms. Lew received a B.S. in Accounting from the University of Wyoming, a J.D., with honors, from the University of Wyoming College of Law, and an L.L.M. in Taxation from Boston University. Majure, Kimberly Tan Partner KPMG LLP Kimberly Tan Majure joined the Washington National Tax Practice of KPMG LLP as a principal in the International Corporate Services Group in Prior to joining the Big Four firm, Kim worked at Washington, D.C., law firm Miller & Chevalier Chartered, and before that was a counsel at law firm Skadden, Arps, Slate, Meagher and Flom. She brings extensive experience in foreign tax structuring, tax planning, and other international tax services, as well as representing clients in IRS audit and appeals proceedings.

15 Kim holds an LL.M in Taxation from the Georgetown University Law Center, a JD from Harvard Law School, and a BA from the University of Virginia Mazur, Mark J. Assistant Secretary of Tax Policy U.S. Department of Treasury Mark J. Mazur currently serves as the Assistant Secretary for Tax Policy of the U.S. Department of the Treasury. In this role, he is responsible for developing, analyzing, and coordinating Treasury's and the Administration's agenda, policies, and guidance on tax issues. Since 2009, Mazur has served as Deputy Assistant Secretary for Tax Analysis, where he advised the Secretary on the economic analysis work undertaken by Treasury's Office of Tax Policy, including studies and reports. Prior to joining the Office of Tax Policy, Mazur spent eight years working for the Internal Revenue Service, where he was the Director of Research, Analysis, and Statistics. Mazur has spent 23 years working for the federal government, including positions at the Congressional Joint Committee on Taxation, the President's Council of Economic Advisors and the National Economic Council under President Clinton, and the Department of Energy. Mazur received a B.A. in financial administration from Michigan State University and a Master's degree in Economics and Ph.D. from Stanford University's Graduate School of Business. McDonald, John D. Partner Baker & McKenzie LLP Mr. McDonald is a partner in Baker & McKenzie, LLP, a member of Baker & McKenzie International, a Swiss Verein. His practice focuses on cross-border mergers and acquisitions, and effective tax rate management through intangibles migration, foreign tax credit planning, repatriation strategies and subpart F planning. Mr. McDonald co-authors a bi-monthly column for Taxes Magazine. He has coauthored articles for Tax Analysts, such as All or Nothing Rule Leaves Taxpayers Empty Handed (with Jeff Maydew) and Common Issues Involving Indian Acquisitions, Dispositions and Spin-Offs (with Parul Jain and Shreya Rao). He also co-authors a tax treatise published by the Research Institute of America entitled U.S. Corporations Doing Business Abroad. Mr. McDonald authored, A Taxing History: Why Corporate Tax Policy Needs to Come Full Circle and Once Again Reflect the Reality of the Individual as Taxpayer,

16 94 Taxes 93 (March 2016). He testified before the Senate Finance Committee on May 24, 2016 in connection with corporate integration. From Fall 2005 to Fall 2006, Mr. McDonald served as a legal advisor to Dr. Anwar Ul-Haq Ahadi, the then Minister of Finance for the Islamic State of Afghanistan. Mr. McDonald assisted with the preparation of the Afghan Income Tax Manual, preparation of tax rulings, and participation in Paris Club negotiations to restructure Afghanistan s debt obligations. Mr. McDonald has a bachelor s degree in accounting from Marquette University and has passed the Certified Public Accountant s exam. Mr. McDonald received his Juris Doctorate from Northwestern University School of Law. McDonald, Michael Financial Economist, Office of Tax Policy U.S. Department of Treasury Michael McDonald is a financial economist in the Business and International Tax Division of Treasury s Office of Tax Analysis since Michael represents the United States at Working Party 6 (Taxation of Multinational Enterprises) of the OECD s Committee on Fiscal Affairs, as well as on a number of WP6 and WP1 (OECD Model Tax Treaty) subsidiary groups. He was Chair of WP6 for the BEPS work on transfer pricing (Action Items 8-10). He is a member of the United Nations subcommittee that drafted the United Nations Practical Manual on Transfer Pricing for Developing Countries, and is a delegate to the OECD s Tax and Development Task Force. He has participated in a number of bilateral income tax treaty negotiations. Prior to joining the Treasury Department, Michael was a transfer pricing economist in the National Tax Department at Ernst & Young ( ). Prior to working at E&Y, Michael was on the Revenue Estimating Division at Treasury s Office of Tax Analysis ( ). Michael received a Ph.D. in economics from Boston College in Merrick, John J. Senior Counsel, Associate Chief Counsel (International) Internal Revenue Service John Merrick is a Senior Level Counsel to the Associate Chief Counsel (International) in the Office of Chief Counsel. Prior to joining Chief Counsel, Mr. Merrick practiced international tax in the national offices of two accounting firms in Washington. He also practiced international and corporate tax in Chicago with an accounting firm and a law firm.

17 Mr. Merrick holds a Bachelors in Business Administration in accounting from Loyola University Chicago, summa cum laude, where he also earned his J.D., cum laude, and was a member of the Loyola Law Journal. He obtained an LL.M. in Taxation from the De Paul College of Law. He also passed the Certified Public Accountant exam. Murray, Fred F. Managing Director, International Tax Services Grant Thornton LLP Fred Murray, B.A., Rice University; J.D. University of Texas at Austin, is currently a Managing Director, International Tax Services in Grant Thornton LLP, U.S. member of Grant Thornton International Ltd, and is an attorney (District of Columbia, Maryland, New York, and Texas (Board Certified in Tax Law, Texas Board of Legal Specialization), and various federal courts) and C.P.A (Maryland and Texas). His experience includes public law and accounting practice, and government service as Deputy Assistant Attorney General in the Tax Division at the U.S. Department of Justice and as Special Counsel to the Chief Counsel for the Internal Revenue Service He is a former Chair of the U.S. Internal Revenue Service Advisory Council (formerly the Commissioner s Advisory Group, ); former Advisor to the International Tax Working Group of the United States Senate Finance Committee; and a former member, Commissioner s Advisory Council, Department of Taxation and Finance, State of New York. Fred serves as an adjunct member of the faculty at Georgetown University Law Center where he teaches courses on international taxation and accounting for income taxes, Sarbanes Oxley Act of 2002, and other issues for corporate tax advisors. Previously, Fred Murray was also an adjunct professor at the University of Texas School of Law, Rice University Jesse H. Jones Graduate School of Management, and the University of Houston Law Center. He has also lectured at the New York University School of Law. He is a former Council Director, governing Council of the American Bar Association Tax Section, and Last Retiring Chair of the Administrative Practice Committee, among various other positions in the ABA Tax Section. He is a Fellow of the American College of Tax Counsel, and a Life Elected Member of the American Law Institute, and a member of the Bloomberg BNA International and Transfer Pricing Tax Advisory Board. Murray, Sue Director Competent Authority Services Division

18 Navarro, Grace Perez Deputy Director, CTPA Organization for Economic Co-operation and Development (OECD) Grace Perez-Navarro is the Deputy Director of the OECD s Centre for Tax Policy and Administration. As such, she plays a key role in the Base Erosion and Profit Shifting (BEPS) Project, improving international tax cooperation, tackling illicit financial flows, promoting better tax policies and engaging developing countries in OECD tax work. Since joining the OECD in 1997, she has held several key positions, including having led the OECD s work on bank secrecy, tax and e-commerce, harmful tax practices, money laundering and tax crimes, the tax aspects of countering bribery of foreign officials, and strengthening all forms of administrative cooperation between tax authorities. Prior to joining the OECD, Ms. Perez-Navarro was a Special Counsel at the IRS Office of the Associate Chief Counsel (International) where she was responsible for coordinating guidance provided to field offices on international tax issues, overseeing litigation of international tax issues, negotiating TIEAs, overseeing the drafting of regulations, rulings and other policy advice and participating in treaty negotiations. In 1993, she was seconded by the IRS to the OECD to launch the revision of the OECD s Transfer Pricing Guidelines. Nichols, Kevin Senior Counsel to the International Tax Counsel U.S. Department of Treasury Kevin Nichols is a Senior Counsel in the office of the International Tax Counsel at the U.S. Department of Treasury. Previously, Kevin was a counsel at Skadden, Arps, Slate, Meagher & Flom and a senior tax counsel for Zoetis Inc. Kevin received his J.D. from Georgetown University and his undergraduate degree from Boston College. Kevin is also a certified public accountant and worked earlier in his career as an accountant for PricewaterhouseCoopers. O Donnell, Douglas Commissioner, LB&I Internal Revenue Service Douglas W. O Donnell is the Commissioner of the Internal Revenue Service s Large Business and International (LB&I) Division headquartered in Washington, D.C. In this role, he oversees tax administration activities for corporations, subchapter S corporations, and partnerships with assets greater than $10 million and is also responsible for administering the tax law that affects individuals with international activity. He serves as the United States Competent Authority in administering the operating provisions of tax

19 conventions and on sensitive and controversial issues related to treaty negotiations. Prior to his current executive appointment, Mr. O Donnell served as the Deputy Commissioner (International) in LB&I. In this role, he was responsible for planning, developing, directing, and implementing a comprehensive servicewide tax administration program that enhanced compliance with international tax laws, ensured consistency in taxpayer treatment, continuously improved systems and processes and effectively allocated resources to meet servicewide international tax administration priorities. Mr. O Donnell previously served in other executive positions including the Assistant Deputy Commissioner, International; Director, Competent Authority & International Coordination; Director of International Compliance, Strategy & Policy; Deputy Director, Pre-Filing and Technical Guidance; and the Director of Field Operations, Heavy Manufacturing and Transportation Industry. Mr. O Donnell began his career with IRS in 1986 as a revenue agent in Washington, D.C. He holds a Bachelor s of Science degree in accounting from the University of Maryland, College Park, and is licensed as a Certified Public Accountant in the state of Maryland. Olson, Pamela F. U.S. Deputy Tax Leader & WNTS Leader PricewaterhouseCoopers LLP Pam is a U.S. Deputy Tax Leader and Washington National Tax Services Leader of PwC. In her role with WNTS, Pam leads a team that includes many former senior government officials and policy advisers. Prior to joining PwC, Pam led the Washington tax practice at Skadden, Arps, and served as assistant secretary for tax policy at the US Department of the Treasury. Pam has represented clients in a broad range of matters, including IRS audits, appeals and litigation; congressional investigations; private letter ruling requests, proposed regulations, and other IRS and Treasury guidance; and in the legislative process. She has advised clients on tax and social security reform and on the structuring of financing, partnership, and M&A transactions. She is a frequent speaker on tax, economic and federal budget matters and has testified before several congressional committees, most recently before the Senate Finance Committee on international tax reform. As assistant secretary for tax policy, Pam had supervisory responsibility for providing the secretary of the treasury with policy analysis and recommendations for all domestic and international issues of federal taxation,

20 including legislative proposals, regulatory guidance, and tax treaties, and for providing the official estimates of all government receipts for the president s budget and treasury cash management decisions. Pam also held positions with the chief counsel s office of the Internal Revenue Service as special assistant to the chief counsel, attorney-adviser in the Legislation and Regulations Division and trial attorney in San Diego District Counsel. In 2000 and 2001, Pam was the first woman to serve as chair of the American Bar Association Section of Taxation. She has served as tax and economic adviser to two presidential campaigns and as tax adviser to the National Commission on Economic Growth and Tax Reform. She has been included repeatedly in Chambers USA: America s Leading Lawyers for Business and The Best Lawyers in America for tax law. Pam served as a Regent of the American College of Tax Counsel and is on the board of several nonprofit organizations. She received the Treasury Department's highest award, distinguished service awards from the Federal Bar Association and Tax Executives Institute, and delivered both the Lawrence Woodworth and Erwin Griswold annual lectures. Pam received her B.A., M.B.A., and J.D. from the University of Minnesota. Oosterhuis, Paul W. Senior International Tax Partner Skadden, Arp, Slate, Meagher & Flom LLP Mr. Oosterhuis is a senior international tax partner in the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom. Mr. Oosterhuis has had extensive experience in international acquisition and disposition transactions, financing arrangements and tax planning for U.S. and foreign-based multinational corporations. He frequently represents clients on controversy matters, as well as regulations and rulings proceedings, with the Internal Revenue Service. In addition, he represents clients in intercompany pricing matters, including docketed Tax Court cases and Advance Pricing Agreement negotiations. He received his B.A. from Brown University and his J.D. Degree from Harvard Law School. After law school he became a Legislation Attorney for the Joint Committee on Taxation, U.S. Congress, and later served as the Committee's Legislation Counsel. He has served as an Adjunct Professor at Georgetown University Law Center, where he taught International Taxation in the Master of Taxation graduate law program. He has lectured at various professional seminars and institutes, has written on a variety of subjects relating to tax matters, and has testified before congressional tax writing committees on various tax legislative issues. He is a

21 member of the bar of the District of Columbia and is admitted to practice in the U.S. Tax Court. Opper, Mark Director, Washington National Tax Deloitte Tax LLP Mark Opper is a principal in the Passthroughs group in the National Tax Office of Deloitte Tax LLP. He works primarily with corporate clients, assisting them with cross-border partnership transactions including joint ventures, internal restructurings, acquisitions, and dispositions. Mark speaks and writes frequently on partnership and international tax topics, and is a regular columnist for the Journal of Passthrough Entities. He also has authored articles that have appeared in Tax Notes, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances (Practising Law Institute), Journal of Multistate Taxation & Incentives, and other publications. Mark is an active member of the AICPA, serving on the S Corporation Taxation technical resource panel. Mark received his B.A. in Economics from the University of Virginia, his J.D. from Wake Forest University, and his LL.M. in Taxation from New York University. Parry, Jeffrey Senior Counsel, Associate Chief Counsel (International) Internal Revenue Service Jeffrey Parry is an attorney at the IRS Office of Chief Counsel (International) where he is a Senior Counsel in Branch 3, which has jurisdiction over the foreign tax credit and expense allocation and apportionment. Prior to joining the Office of Chief Counsel, Mr. Parry practiced tax law in New York as an associate at Cahill Gordon & Reindel and Paul Hastings. Mr. Parry received his B.A. and B.S., from the University of Utah and his M. Music from Wichita State University. He received his J.D. from Columbia University School of Law and his LL. M. in Taxation from New York University. Peroni, Robert J. The Fondren Foundation Centennial Chair for Faculty Excellence and Professor of Law The University of Texas School of Law Professor Robert Peroni practiced law in Chicago and San Francisco and was a member of the Tulane law faculty (from ) and the George Washington University law faculty (from ) before joining the Texas

22 law faculty in Fall He was the first recipient of Tulane's Felix Frankfurter Distinguished Teaching Award. During the academic year, Professor Peroni served as a professor-in-residence in the Office of Chief Counsel of the IRS. He was a recipient of George Washington University Law School's Distinguished Faculty Service Award, selected by vote of the 1991 and 1993 graduating classes. He held the title of the Robert Kramer Research Professor of Law while on the G.W. law faculty. Professor Peroni also has taught as a visiting professor on the law faculties of New York University, the University of Pennsylvania, the University of Texas, UCLA, Northwestern University (where, during the academic year, he served as the J. Landis Martin Visiting Professor of Law and Business, and, during the Fall 2006 semester, he served as the Jack N. Pritzker Distinguished Visiting Professor of Law), and Georgetown University. In 2006, Professor Peroni was the recipient of the Texas Exes Faculty Teaching Award for excellence in teaching at the University of Texas School of Law. In 2012, he was appointed an Adjunct Research Fellow at Monash University s Department of Business Law and Taxation. Professor Peroni's research and teaching interests are in the areas of federal taxation, law and economics, international trade, and professional responsibility and legal ethics. He has been the academic co-chair of the Institute s Advisory Board since 1991, and also is the academic co-chair of the biennial Parker C. Fielder Oil and Gas Tax Conference, co-sponsored by the IRS and the University of Texas School of Law. Professor Peroni has co-authored six books, including the three-volume treatise U.S. International Taxation, and has written many articles that appear in a variety of law journals. He is currently serving as a Vice Chair of the ABA Section of Taxation s Committee on Foreign Activities of U.S. Taxpayers and previously served as the Chair of the AALS Tax Section. He is a Fellow of the American College of Tax Counsel. Professor Peroni has taught a number of courses in the NYU/IRS Continuing Professional Education program and has lectured at numerous CLE programs on a variety of legal topics. Professor Peroni received a B.S.C. degree in Accounting from DePaul University in 1973, a J.D. degree from Northwestern University School of Law in 1976, and an LL.M. (in Taxation) from New York University School of Law in Plowgian, Michael Principal, Washington National Tax KPMG Michael is a principal in KPMG s Washington National Tax Office for International Tax. He advises multinational corporations regarding international tax planning and policy, with a particular focus on helping clients address the implications of the OECD/G20 BEPS Project, FATCA, and the OECD/G20 Common Reporting Standard. Michael is a member of the