Global Transfer Pricing Forum - New York 2017

Overview

The Global Transfer Pricing Forum returned for its 17th year to New York on 8 & 9 May. The event drew on International Tax Review and TP Week’s 27 year editorial history, providing tax and transfer pricing professionals with objective and critical insights into the TP landscape.

The current transfer pricing environment is rapidly changing, accelerated by the OECD’s BEPS initiative. However, even with the publication of the latest BEPS guidelines in October 2015, taxpayers still face high levels of uncertainty in trying to mitigate risk from the implementation of new regulations and gauge tax authority response to proposed changes. The role of technology in managing TP obligations is also a trend that taxpayers are seeking to implement in order to control and streamline their working processes.

These issues and more were discussed in Q&A style panels, drawing on contributions from the delegation to directly address what the audience wanted to know with the aim of facilitating free and transparent debate. As such, over 200 taxpayers and transfer pricing professionals attended the Forum to openly share their experiences.

Attendees are also welcome to join the cocktail reception at the end of day one, giving delegates and speakers alike the chance to network informally.

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The Global Transfer Pricing Forum is an annual event taking place twice yearly in Europe and North America. For advance notification of the event's return, register your interest here or email registrations@tpweek.com 


REGISTRATION & ENQUIRIES
Alicia Sprott
+44 (0) 207 779 8334
registrations@tpweek.com


SPEAKING ENQUIRIES
Salman Shaheen
+44 (0) 207 779 8791
salman.shaheen@euromoneyplc.com


SPONSORSHIP ENQUIRIES
Andrew Tappin
+44 (0) 207 779 8661
atappin@euromoneyplc.com


 

Agenda

 

Download the brochure here

DAY ONE - 8 MAY

08.15 Registration and breakfast

08.50 Chair’s introduction and opening remarks

Salman Shaheen, Managing Editor, International Tax Review
John Wells, Principal, Deloitte

 

09.00 Keynote address from the OECD

Grace Perez-Navarro, Deputy Director, Centre of Tax Policy and Administration, OECD



09.30 Transfer Pricing Reporting and Documentation: An update on CbC and master file/local file strategies

Once a fringe topic, CbCR is now a reality taxpayers have to grapple with. This panel will look at how taxpayers are tackling the new reporting challenges and discuss emerging best practices.

Moderator: Paul Riley, Global Transfer Pricing Leader, Senior Transfer Pricing Partner – Australia, Deloitte
Ognian Stoichkov, Global Transfer Pricing Director, PepsiCo
Luis Carrillo, Director – Transfer Pricing, Bureau van Dijk
Nicole Williams, Global Transfer Pricing Manager, Celanese
Kristine Riisberg, Partner, Deloitte

10.45 Coffee break and networking

11.05 Blockchain and the TP tech revolution

Tech experts say Blockchain represents a digital revolution on the same level as the advent of the Internet. This session will look at the impact of Blockchain on Operational Transfer Pricing as well as other innovative tech solutions.

Boris Nemirov, Tax Principal, NE/NY TP Group Leader, Global TP Technology Leader, Deloitte
Sam Cicogna, Vice President and Head of ONESOURCE Transfer Pricing, Thomson Reuters
Bob Norton, Specialist Leader, Deloitte

12.20 Keynote address: US Transfer Pricing Tax Administration and Enforcement

Tom Kane, Division Counsel, Office of Large Business & International Division, Internal Revenue Service

12.50 Lunch and networking

13.40 Keynote address and Q&A: Tax Policy

Jonanthan Traub, Managing Principal, Tax Policy Group, Deloitte

14.30 Dispute Resolution Update

In the age of transparency, TP controversy is all but guaranteed. This panel will focus on some of the most significant court cases around the world, lessons learned from them, and strategies to prevent things getting that far.

Moderator: Dave Varley, Principal, Deloitte
Carlos Pérez-Gómez Serrano, Director of Transfer Pricing Audits, Mexican Tax Administration Service
Santiago Menéndez, Director General, Spanish Tax Agency (AEAT)
Kerwin Chung, Principal, Deloitte
Simón Somohano, Lead Partner, Transfer Pricing Services, Latin America and the Caribbean Region, Deloitte

15.45 Coffee break and networking

16.05 Intercompany contracts in light of BEPS

After the publication of the final OECD reports on BEPS Actions 8-10 and Action 13, intercompany contracts between related parties are the starting point of a transfer pricing analysis. This panel will look at their increased importance in the post-BEPS world.

Moderator: Joe Tobin, Senior Manager, Global Transfer Pricing, Deloitte
Peter De Nicola, Director of Taxes, Fujifilm
Scott Campbell, Director, International Tax, AT-PAC
Mike Manuel, Director, Transfer Pricing, Texas Instruments
Andrew Kim, Partner, Fenwick & West

17.20 Close of day one

 

17.30 Cocktail reception

DAY TWO - 9 MAY

08.15 Registration and breakfast

08.50 Chair’s introduction and opening remarks

Salman Shaheen, Managing Editor, International Tax Review
Paul Riley, Global Transfer Pricing Leader, Senior Transfer Pricing Partner – Australia, Deloitte

09.00 Keynote address: US and global business update

Lou Dobbs, Host, Lou Dobbs Tonight

10.00 New Transfer Pricing Guidelines: Update on BEPS Actions 8-10 by region

This panel will take a global look at how BEPS Actions 8-10 are being implemented and will give participants the chance to hear directly from tax authorities around the world.

Moderator: Darcy Alamuddin, Tax Principal and Head of Operations – Deloitte US Transfer Pricing
Sami Koskinen,
Special Adviser for the Large Taxpayers' Office, Finnish Tax Administration
Firas Zebian,
Partner, Deloitte

11.15 Coffee break and networking

11.35 Value chain analysis and global profit split

Authorities are increasingly demanding that multinationals align transfer pricing outcomes with economic substance, leading to a greater focus on how the value generated by functions, assets and the assumption of risks is attributed to different tax jurisdictions. This session will drill into value chain analysis and global profit split.

Shanto Ghosh, Principal, Transfer Pricing, Deloitte
Arin Mitra, Principal, US Intangibles Leader, Deloitte

12.50 Lunch and networking

13.40 Keynote address: US and global economic update

Ira Kalish, Chief Global Economist, Deloitte

14.30 Intellectual property planning in a changing world

This panel will discuss transfer pricing planning in intellectual property, including a look at the continuing viability of IP transfers from the US under revised IRC Sections 367 and 482 regulations.

Moderator: Philippe Penelle, Principal, Deloitte
David Forst, Practice Group Leader - Tax, Fenwick & West
Phyllis Cambogna, Vice President, Tax, Synchronoss Technologies
Abhishek Chawla, Tax Director, Asia & Pacific, Xerox
Jay Das, Principal, Deloitte

15.45 Coffee break and networking

16.05 Hot topics in transfer pricing

This session will take you through some of the hottest issues in transfer pricing today, touching on debt/equity, emerging markets and state aid.

Robert Plunkett, Principal, Deloitte
Bradley Fein, Principal, Deloitte

17.20 Close of conference

Speakers

Speakers in 2017 included:

 

Keynote speaker: Grace Perez-Navarro

Alan Krueger   Deputy Director, Centre of Tax Policy and Administration
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, 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. 



Keynote speaker: Tom Kane

Jivan Datta   Division Counsel, Office of Large Business & International Division
Internal Revenue Service

Tom Kane is the division counsel for the Office of Large Business & International Division Counsel function within the IRS Office of Chief Counsel in Washington DC. Within the IRS, the LB&I Division handles large business and international tax issues. As LB&I division counsel, Kane oversees the tax litigation conducted by the IRS in the US Tax Court and legal advice provided to the IRS by over 300 LB&I attorneys and paralegals located throughout the country. He previously served as the division counsel with the Tax Exempt & Government Entities Division Counsel function. Kane received his JD 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.



Keynote speaker: Jonathan Traub

Alan Krueger  

Managing Principal, Tax Policy Group
Deloitte

Jonathan Traub joined the Washington National Tax practice of Deloitte Tax in June 2012 as managing principal of its Tax Policy Group. With extensive experience in the legislative arena, especially in tax policy, he is able to provide clients with critical insights on developments in tax policy and politics, helping them anticipate legislation and the potential impacts on their businesses.

Traub leads a team that identifies, evaluates and monitors legislative proposals, and interprets the practical issues surrounding the application of tax proposals on behalf of Deloitte’s clients and that relays those insights through multiple channels, including weekly newsletters and deeper dive pieces on key developments.

Traub was previously the staff director for the Committee on Ways and Means of the US House of Representatives, his most recent senior staff position in the US House of Representatives. During his tenure as staff director for the Committee on Ways and Means, Traub was responsible for developing legislative policies and strategy on issues in the Committee’s jurisdiction, including taxes, healthcare and trade.

He received his bachelor’s degree from Haverford College and juris doctor from the University of Virginia.



Keynote speaker: Lou Dobbs

Jivan Datta   Host
Lou Dobbs Tonight

Lou Dobbs, Emmy award-winning host of Lou Dobbs Tonight on the Fox Business Network is a legendary broadcaster, best-selling author and one of the most respected and insightful voices on politics, economics, society and business. For three decades, Dobbs has brought an unwavering American perspective to the most important issues of our day, whether national security, sustainable economic growth and prosperity, global business, finance and trade, or education and public investment.

Provocative and fearless in his analysis of the leading issues in American society, Dobbs challenges the status quo at home and abroad. He lays out solutions for moving America forward and restoring the American dream for our middle class, and those who aspire to it, and small businessmen and women. He offers prescriptions to assure our national security, to build business, create jobs, rejuvenate the nation's manufacturing sector, invigorate education and innovation and secure our nation's borders and ports. Dobbs says our strength of will and independence of mind assure America's return to prosperity, so long as we elect leaders of like spirit who preserve our great national values and ideals.

Dobbs hosts three financial radio reports daily. He has also written important examinations of the American political economy that in some instances anticipated by years many of the issues that challenge our nation today. Dobbs is also the author of numerous best-selling books including Upheaval (January, 2014) dependents Day: Awakening the American Spirit (2007), War on the Middle Class (2006), and Exporting America (2004).



Keynote speaker: Ira Kalish

Alan Krueger  

Chief Global Economist
Deloitte

Ira Kalish is the chief global economist of Deloitte Touche Tohmatsu. He is a specialist in global economic issues as well as the effects of economic, demographic, and social trends on the global business environment. He has written about the economies of Western Europe, Eastern Europe, Southeast Asia, China, Japan, Mexico and South America, and has also written extensively on global consumer markets.

Among Kalish’s recent publications were the quarterly Global Economic Outlook of which he is the managing editor; the annual Global Powers of Retailing report; China and India: Comparing the World’s Hottest Consumer Markets; China and India: The Reality Beyond the Hype, Budget Deficits: Why All the Fuss, an article in CFO Journal, and Mind The Gap, an article in Deloitte Review on changing income distribution.

Kalish advises Deloitte clients as well as Deloitte’s leadership on economic issues and their impact on business strategy. In addition, he has given numerous presentations to corporations and trade organisations on topics related to the global economy. Kalish also serves on the BIAC Economic Policy Committee which advises the OECD on macroeconomic policy issues. He is widely traveled and has given presentations in 47 countries on six continents. Kalish has been widely quoted in the news media; his remarks have been published by the Wall Street Journal, The Economist, The Financial Times, USA Today, The Washington Post, and US News & World Report. He has appeared on CNN, CBS News, CNBC, PBS and BBC World Service. Prior to his work at Deloitte,

Kalish was chief economist at Retail Forward, a director at PwC, vice president at Bankers Trust, corporate economist at the Eastman Kodak Company, and researcher at the Institute for International Economics.



Scott Campbell

Scott Campbell  

Global Tax Director
At-pac Complete Scaffolding

A graduate from the University of Arkansas School of Law in 1997, Scott Campbell has managed global transfer pricing/international tax operations for MNEs since 2007. He was responsible for transfer pricing controversy, procedures, policy and compliance for Celanese ($5 billion in intercompany tangible product transactions annually) and for FMC Technologies ($2 billion in intercompany tangible product transactions annually). Campbell is experienced in Asia, Europe, Africa, Australia and Americas international tax regimes as each involve compliance, strategic planning and controversy. He has also successfully resolved transfer pricing audits in the US, Holland, Japan, Korea, France, Germany, Canada, Brazil and India. Campbell is currently the global tax director - international tax at AT-PAC Complete Scaffolding Solutions, a Georgia-based, privately held MNE and an industry leader in the scaffolding marketplace.



Abhishek Chawla

Abhishek Chawla  

Tax Director, Asia & Pacific
Xerox

Abhishek Chawla is a qualified lawyer and a chartered accountant having 15+ years’ experience of working in consulting and industry. He holds a master’s degree in international tax law from Vienna University, Austria. Before joining Xerox, he worked with Big Four accounting firms and law firms.

He has extensive experience in tax-structuring inbound and outbound investment, international tax treaty issues, tax controversy and dispute resolution, tax accounting and transfer pricing issues. He currently serves as tax director, Asia-Pacific for Xerox and deals with all facets of tax laws including corporate income tax, indirect tax, transfer pricing.

Chawla has been a member of various tax committees of leading business chambers such as Confederation of Indian Industry (CII). He is a frequent guest speaker at various national and international tax conferences.

He has authored several articles on taxation that have been published by leading business dailies and has co-authored a book titled International Group Financing published by Linde Verlag, Austria.



Peter De Nicola

Jivan Datta   Director of Taxes
Fujifilm Holdings America

Peter De Nicola heads the tax function for Fujifilm’s Americas region. He has over 40 years of diverse tax experience, including 25 years at Fujifilm. In his role as Director of Taxes, De Nicola oversees the company’s transfer pricing policies, domestic and international tax compliance for North and South America and is heavily involved in mergers, acquisitions and restructurings. Prior to joining Fujifilm, he held various tax management positions with General Signal, Emery Worldwide and Siemens.

A Certified Public Accountant, De Nicola earned a BS in Accounting and an MBA in Taxation from New York University. He serves on the Board of Directors of the Tax Executives Institute and is President of the Stamford Tax Association. In addition to authoring numerous articles on taxes and investments, he has been interviewed in the Wall Street Journal and on Bloomberg Television. He is a contributor to a text book on mergers and acquisitions which will be published later this year by MIT Press.



Michael Manuel

Michael Manuel  

Director, Global Transfer Pricing
Texas Instruments

Mike Manuel is director, global transfer pricing in Texas Instrument’s (TI) corporate tax department.

TI, a global semiconductor company with about 30,000 employees in more than 30 countries, designs and makes semiconductors to sell to electronics designers and manufacturers all over the world.

Manuel is responsible for all aspects of transfer pricing at TI including strategy, policy, compliance and controversy. He has worked in transfer pricing at TI for 18 years.

He has held previous positions in finance at TI as a Semiconductor Division controller, Semiconductor Financial Planning Manager, TI’s Consolidation Accounting Manager, and internal auditor. Before coming to TI Manuel worked in public accounting for Touche Ross. He is a CPA and cum laude graduate of the University of Texas, McCombs School of Business.

In addition to transfer pricing, Manuel is director, global tax provision for TI. He has responsibility for all aspects of the tax provision including application of ASC 740 and publicly reported income tax disclosures and communication.



Santiago Menéndez

Santiago Menendez  

Director General
Spanish Tax Agency (AEAT)

Santiago Menéndez took office as director general of the Spanish Tax Agency on June 28 2013.

He holds a bachelor degree in economics and business management.

Menéndez has developed his professional career within the Spanish Tax Agency, occupying some high ranking positions such as director of the tax collection department, head of the regional office of Asturias and head of the National Office for Fraud Investigation.



Ognian Stoichkov

Ognian Stoichkov  

Global Transfer Pricing Director
PepsiCo

Ognian Stoichkov serves as global transfer pricing director for PepsiCo. He has responsibility for the global transfer pricing policy and strategic projects for the company, as well as Americas transfer pricing. Prior to joining PepsiCo, Stoichkov spent 14 years with Big Four transfer pricing practices in Detroit, Short Hills, NJ and New York.

He has a BA in economics from Reed College, a MA in Economics and PhD candidacy in economics from the University of Michigan, Ann Arbor.



Nicole Williams

Jivan Datta   Global Transfer Pricing Manager
Celanese Corporation

Nicole Williams joined Celanese Corporation, a global technology leader in the production of specialty materials and chemical products which are used in most major industries and consumer applications, in 2009 and is the Global Transfer Pricing Manager. Her responsibilities include transfer pricing planning, implementation, documentation, audits, governance, and transfer pricing operations. Prior to joining Celanese, Williams worked at PwC in the federal tax practice.

Williams holds a B.S in Accounting and a M.S. in Tax from the University of Texas at Dallas.



Phyllis Cambogna

 

Vice President, Tax
Synchronoss Technologies



Sami Koskinen

 

Special Advisor
Finnish Tax Administration



Carlos Pérez-Gómez Serrano

 

Director of Transfer Pricing Audits
Mexican Tax Administration Service



Eduardo Goldszal

Eduardo Goldszal  

Finance Senior Director and Head of Transfer Pricing
NCR Corporation

Eduardo Goldszal is Finance Senior Director and Head of Transfer Pricing at NCR Corporation, a US-based technology company with over 35,000 employees and operations all over the globe. Eduardo has a Ph.D. in economics from the New School in New York City. Before
joining NCR in 2011 he was a Tax Partner with KPMG. While at KPMG, Eduardo led the transfer pricing practices in the Miami and Lisbon (Portugal) offices. At NCR, Eduardo is in charge of global transfer pricing. He is involved in different aspects of tax controversy, alternative dispute resolutions, compliance, FIN 48 provision, and the day-to-day operational transfer pricing of the company.



Bradley Shumaker

Bradley Shumaker  

Tax Counsel, Transfer Pricing
Zimmer Biomet

Bradley Shumaker currently serves as Tax Counsel, Transfer Pricing for Zimmer Biomet, a medical device manufacturer based in Warsaw, Indiana. He has been involved with working both U.S. and foreign cost sharing and transfer pricing issues from a corporate perspective since 1997. His previous experience includes serving as the global transfer pricing director for eBay, and as the U.S. transfer pricing focal point for Royal Dutch Shell.



Marcelo Vicentini

Marcelo Vicentini  

Head of Tax
Standard Chartered Bank (Brazil)

Marcelo Vicentini has more than 15 years' experience in tax, with vast knowledge of Latin America tax law, transfer pricing and regulatory rules (such as FATCA, CRS and BEPS). He actively participates in the development of new financial products, national and international structured transactions. Currently, he is responsible for the tax department at Standard Chartered Bank Brazil and oversees Latin America. On top of tax matters, he is also in charge of finance governance for Brazil, dealing with operational risk and capital management. He also worked for BNP Paribas, Standard Bank, ING and KPMG.

A frequent speaker at national and international conferences, Vicentini is a lawyer, specialised in tax, with a Master's degree in financial and economic law from São Paulo University. He is also professor of General Theory of Tax Law and Financial and Capital Markets taxation at Insper-Institute of Education and Research (LLM Program).

 

 

Nick Leak

Nick Leak  

Transfer Pricing Lead
Royal Dutch Shell

Nick has been a transfer pricing lead within Royal Dutch Shell’s global transfer pricing team, based in London, United Kingdom since 2010. As a specialist in transfer pricing with over 12 years of transfer pricing experience, Nick has gained wide experience and expertise across the transfer pricing discipline. Nick is currently responsible for leading the global transfer pricing advice for Shell’s corporate treasury, captive insurance and asset management businesses. He has an interest and specialism in the financial services area of transfer pricing, particular corporate treasury.

Nick has been an active contributor to the Business and Industry Advisory Committee to the OECD and the Confederation of British Industry especially in regards to the OECD’s Base Erosion and Profit Shifting project. Nick has previously been a speaker on corporate treasury transfer pricing at the Global Transfer Pricing for the Energy and Extractive Industries Extractive Industries Conference. Nick has previously advised clients in a broad range of industries across financial services, energy, consumer products and technology.

Prior to joining Shell, Nick worked with PricewaterhouseCoopers in Melbourne, Australia (2003-2008) and later with Ernst & Young’s Financial Services Transfer Pricing team in London, U.K. (2008-2010).

Nick has Batchelor of Commerce Degree from Melbourne University majoring in accounting, economics and finance and has been a member of the Institute of Chartered Accounts of Australia since 2006.

 



Clay Ayers

Clay Ayers  

Director, Head of Tax
K2M

Clay is the head of the tax function at K2M, a publically traded medical device manufacturer based outside Washington DC. Clay is responsible for tax planning/structuring, compliance/governance and cash repatriation on a worldwide basis.

K2M is the third pre-IPO company in Clay’s career in which he has built a global tax function from scratch with responsibilities for structuring, tax accounting and compliance/governance. In addition to IPO start-ups Clay has been the head of tax at two multi-billion dollar companies, Watson Wyatt & Co and Serco-NA, Inc. which were also headquartered in the Washington DC area.



Brad Del Matto

Brad Del Matto  

Global Head of Tax
Nintex

Brad Del Matto, senior tax executive with over 20 years of diverse tax, legal, financial and managerial experience, is Global Head of Tax at Nintex where he is responsible for worldwide tax matters.

He was Managing Director at Tax Management Services prior to Nintex, providing a virtual tax function to small/medium sized companies without significant internal tax resource. Before that he was with Yahoo! as Senior Director, International Tax responsible for all US tax aspects of international operations. And he was VP of Tax at Dendreon Corporation.

Del Matto was at Microsoft for many years in international leadership positions. He received his
LL.M. from NYC Law.



Keith Brockman

Keith Brockman  

former EMEA Tax Director
Mars

Keith has been VP of Tax & Treasury for several US based multinationals, and is a former member of the Mars Tax Leadership Team.

He serves on the Tax Practitioner's Advisory Board for KIMEP Law School in Kazakhstan, is a frequent lecturer and author, including the Brockman Brief in International Tax Review, and also envisioned and created an International Tax Best Practices blog; strategizingtaxrisks.com.



David Campkin

David Campkin  

Group Tax Director
BBC

David is a Chartered Accountant, specialising in Corporate Tax since 1991. He is in charge of the BBC’s global tax affairs, and has been heavily involved in all major transactions and structuring since he joined the BBC in 1997. Although the BBC’s Charter obligations are funded by the licence fee, with a unique tax treatment, commercial activities are undertaken by a £1bn MNG. David is also a Director of several BBC subsidiaries, and a school Governor in Buckinghamshire.

A regular speaker at tax conferences, David previously advised clients whilst working at PricewaterhouseCoopers, and KPMG before that.



Lucia Fedina

Lucia Fedina  

Director, Transfer Pricing
Deutsche Bank

Lucia Fedina is a Director at Deutsche Bank in New York, responsible for the Americas’ transfer pricing. Lucia’s experience includes 20+ years’ work as an economist; focusing on transfer pricing for the last 17 years. Prior to joining Deutsche Bank, Lucia worked as a transfer
pricing economist at the Big 4 firms, where she worked with clients in financial services, pharmaceuticals and high tech industries specialising in transactions primarily
related to the pricing of risks. Lucia is an author of multiple articles and papers related to pricing of
guarantees, profit splits, real estate, asset management and insurance transactions. Lucia dealt with various controversy issues and APAs working with tax authorities of the OECD and developing countries.



Darcy Alamuddin

Darcy Alamuddin   Tax Principal and Head of Operations – US Transfer Pricing
Deloitte

Darcy Alamuddin is a principal in the Chicago office of Deloitte Tax’s transfer pricing practice. With 18 years of experience, she provides multinational clients with tax consulting services on many aspects of transfer pricing and international taxation. Alamuddin has worked on a wide variety of transfer pricing issues which include planning, strategy review, audit defense, and documentation engagements. In the context of these engagements, she works with clients in the areas of structuring, tax minimisation, and foreign tax credit planning. Her projects have covered: headquarters services; inbound and outbound tangible product transactions; outbound migration of intangible product transactions; licensing of intangible assets; business model optimisation projects; and the provision of contract R&D and trading services. Alamuddin has served French, German, Japanese, UK, and US multinational corporations.

Specifically in respect to headquarters services projects, Alamuddin has performed 15 to 20 of these headquarter studies for various clients. The results of these studies have supported service fees to be changed a quantifying the service fee amount as part of a bundled system royalty. Additionally Alamuddin has suggested these changes with great success in local country audits in the US, UK, Canada, Germany, and the like with the creation of local country reports.



Kerwin Chung

Kerwin Chung   Principal
Deloitte

Kerwin Chung is the managing principal of Deloitte’s Washington National Tax Transfer Pricing Team and leader of Deloitte’s US Advance Pricing Agreement and Mutual Agreement Procedure Team. Chung graduated from Harvard Law School and has more than 20 years of transfer pricing experience. Chung has been selected as one of the World’s Leading Transfer Pricing Advisors by Euromoney Legal Media Group for every edition since 2002.

Chung’s practice includes representing clients before the IRS and foreign tax authorities regarding transfer pricing and OECD BEPS tax matters, including negotiating Advance Pricing Agreements (APAs) and Mutual Agreement Procedure (MAP) cases.



Jay Das

Jay Das   Principal
Deloitte

Jay Das has extensive transfer pricing experience and has provided several top multinational companies (including Fortune 500 companies) with valuation and economic consulting services involving business model optimisation strategies, mergers and acquisitions, implementation of IP migration strategies, headquarter services, international tax transfer pricing planning, and restructuring and reorganisation of international operations as well as controversy management and dispute resolution. He is also actively involved in training, and has developed training materials for Deloitte’s US and global transfer pricing practice and has instructed at several internal and external events.

Prior to joining Deloitte Tax, Das was an analyst with Merrill Lynch in the Investment Banking division, was a research assistant at the University of California, San Diego in the physics department and was a software developer for NASA EKK program.

Das earned BA degree in mathematics and economics from the University of California, as well as a MBA degree from Haas School of Business, University of California, Berkeley.



Shanto Ghosh

Shanto Ghosh   Principal, Transfer Pricing
Deloitte 

Shanto Ghosh is a principal in Deloitte’s Transfer Pricing practice in the US and is based in Boston. He has over 15 years of transfer pricing experience and leads Deloitte’s transfer pricing team in the Greater Boston area.

Ghosh has significant experience in advising clients from the life sciences, technology (including media and telecom), and automobile sectors. He has been actively involved in assisting clients with their global transfer pricing policy and documentation, and has implemented a number of large-scale global supply chain restructuring projects. He has significant experience in assisting clients on transfer pricing litigation and dispute resolution strategies and has been recognised in Euromoney Legal Media Group’s World’s Leading Transfer Pricing Advisers four times in a row.

He is a frequent speaker at international conferences across the globe and has published a number of high-profile articles. He has advised the Government of India on transfer pricing policy matters and has also been involved with the OECD and the WCO in joint discussions related to the interplay between customs and transfer pricing valuation.



Arin Mitra

Arin Mitra   Principal, US Intangibles Leader
Deloitte

Arin Mitra is a principal and a senior economist in the transfer pricing practice of Deloitte Tax based in Washington DC. He leads the Washington DC based transfer pricing team of Deloitte. Prior to relocating back to the US in 2004, he co-led Deloitte’s Tokyo transfer pricing practice (2001 - 2004). He also served in Deloitte’s Sydney (as lead economist; 1998 - 2000), Los Angeles, Chicago and Washington DC offices over the last 14 years.

Mitra is primarily engaged in economic and financial analysis of transactions between related entities of a multinational enterprise for the determination of arm’s length prices, in valuation of intangible property, and in the measurement and benchmarking of risk-return trade-offs. He specializes in dealing with tax authorities on transfer pricing issues, including audits, competent authority negotiations and Advance Pricing Agreements (APAs). He has developed and negotiated pricing methodologies for over 30 APAs, mostly bilateral, involving the US, Japan, Australia, Canada and China. He has been recognized by the Euromoney as well as the International Tax Review as a leading transfer pricing advisor in the US.



Boris Nemirov

Boris Nemirov   Tax Principal, NE/NY TP Group Leader, Global TP Technology Leader
Deloitte

Boris Nemirov is a tax principal and leads the Northeast Transfer Pricing (TP) Group of Deloitte Tax. His experience includes 18 years of transfer pricing economic consulting, since joining Deloitte in 1999. Over the years, Nemirov consulted on a multitude of transfer pricing issues and led the preparation of transfer pricing documentation and planning studies in a variety of industries for both inbound and outbound taxpayers. In addition, he has extensive expertise in intangible property (IP) migration, supply chain planning, business model optimization, post-merger integration, valuation of entities and intangible assets, cost sharing/derivation of platform contributions and development of royalty rates. Nemirov has also consulted on and defended under audit and in appeals headquarters cost allocation issues. Furthermore, he specializes in financial transactions transfer pricing focusing on intercompany financing, debt capacity, factoring, risk transfers, guarantees and cash pooling arrangements. He also leads numerous large scale global transfer pricing documentation engagements for multinational clients.

Nemirov works on planning projects aimed at enhancing and streamlining, from a tax and transfer pricing perspectives, business changes and cost-cutting initiatives of multinational companies. Recently, he led, from a transfer pricing perspective, an IP migration project for a multinational technology company, looking to consolidate IP from several countries into its Technology Capabilities Center. Along with performing the valuations of the IP for this project, Nemirov advised on future “BEPS-ready” operating model and optimal transaction flow structure to ensure proper substance for sustaining residual IP returns. He also engages in supply chain planning projects for companies either in post-merger integration mode or looking to improve the IP ownership structure for better alignment with business objectives and natural organic growth of the organizations.



Bob Norton

Bob Norton   Specialist Leader
Deloitte

Bob brings 30+ years of international tax, tax technology and process improvement experience with large multinational corporations to his role as Specialist Leader. For the first half of his career, Norton led the tax department of a high growth, publicly held multinational. Over the last twelve years he has focused on creating and implementing transformation-enabling technology solutions to aid tax departments in evolving to new operating models focused on streamlined tax data management, tax analysis, strategy and risk management.

Over the last two years Bob has been immersed in the OECD’s Base Erosion and Profit Shifting Action plans, US and EU tax policies and how they impact the transfer pricing operations of the Fortune 500.

He has experience in a variety of industries including technology, retail, manufacturing and insurance. Bob sits on the Editorial Advisory Board of Financial Executives magazine and is a member of the Tax Council, US Council of International Business Tax Committee, Financial Executives International, AICPA and PICPA.



Philippe Penelle

Philippe Penelle   Principal
Deloitte

Philippe Penelle is a principal with the Washington National Tax office of Deloitte Tax, specialising in designing, valuing, and defending transactions that involve the transfer of intellectual property rights. He brings over 17 years of professional transfer pricing experience assisting his multinational clients set-up, maintain, document and defend transfers of intellectual property rights through cost sharing arrangements, contributions to international partnerships under 26 US Code §704, contributions to corporations under 26 U.S. Code §367, and licensing arrangements involving specific allocations of fixed cost funding commitments.

Penelle currently serves as the co-chair of the United States Council for International Business (USCIB) Transfer Pricing Subcommittee. He is actively involved in the Base Erosion and Profit Shifting (BEPS) conversations with the OECD, the US Treasury Department, and with the international business community. His involvement has included the drafting of comments submitted on behalf of Deloitte Tax to the OECD, providing input to the USCIB’s and to the Business and Industry Advisory Committee to the OECD’s (BIAC), as well as being an invited speaker at the OECD public consultations in Paris, France.



Robert Plunkett

Robert Plunkett   Principal
Deloitte

Robert Plunkett is the managing principal of Deloitte’s Transfer Pricing Group in the east region. In addition, he leads the firm’s Financial Services Transfer Pricing practice.

Plunkett has served a wide array of the firm’s clients, including those involved in banking, investment banking, asset management, insurance, insurance brokerage, private equity, and hedge fund management. In serving these and other clients, he has worked on contemporaneous documentation, planning, audit defense, and APAs.



Kristine Riisberg

Kristine Riisberg   Partner
Deloitte

Kristine Riisberg is a principal in Deloitte’s New York office. She has more than 16 years of transfer pricing and international tax experience with Deloitte and spent four years in Deloitte’s Washington national tax office.

Riisberg has extensive experience in company financial and quantitative research analysis and industry data analysis in a wide range of industries. She has prepared economic analyses, documentation, planning, competent authority requests and cost sharing studies for clients across a range of industries including media and entertainment, telecommunications, high-end luxury goods and financial services.

Riisberg has an international background and experience working in Deloitte transfer pricing teams in Copenhagen and London building up an extensive knowledge of global transfer pricing matters. She is the global and US transfer pricing all-industries programme leader, and the Americas transfer pricing leader of the technology, media & telecommunication industry programme. She assumes the global lead tax partner role for the world’s largest container shipping conglomerate, the global lead TP role for one of the world’s largest media conglomerates and the global lead TP role for the largest European-headquartered consumer and industrial goods conglomerate.



Paul Riley

Paul Riley   Global Transfer Pricing Leader, Senior Transfer Pricing Partner – Australia
Deloitte

Paul Riley is Deloitte’s global transfer pricing leader and is a senior transfer pricing partner in our Deloitte Australia Tax & Legal practice. He has over 30 years of experience, including 10 years with the Australian Taxation Office and 20 years in public practice, with experience serving clients throughout Australia, Asia Pacific and the US. Riley spent two years with Deloitte’s Global Transfer Pricing team in its Los Angeles office, working with US multinational companies on a variety of transfer pricing assignments. He has held many senior positions during his 18 year career at Deloitte including managing partner of Deloitte Australia Tax & Legal (2012-2015), Victorian tax & legal leader (2011) and Deloitte Asia Pacific transfer pricing leader (2009-2012).

Riley is experienced in all facets of transfer pricing, including successfully resolving a number of transfer pricing audits and advance pricing arrangements (APA), large-scale global, regional and local documentation studies, analysis and review of business restructures and IP alignments, and planning for cross-border transactions for global businesses. His work is across numerous industries including FMCG, energy and resources, financial services and manufacturing. Riley’s major clients include Treasury Wine Estates, Schlumberger, Shell, Visy Industries, and Brambles. Recently, he successfully negotiated a complex tax law dispute for a major oilfield services company.



Simón Somohano

Simon Somohano   Lead Partner, Transfer Pricing Services, Latin America and the Caribbean Region
Deloitte

Simón Somohano is a tax partner based in in Mexico City and Tijuana responsible for Deloitte’s transfer pricing practice in Latin America and the Caribbean region.

He has more than 26 years of experience in the application of tax, economic and financial criteria in transfer pricing, anti-dumping/subsidy investigations, valuation analysis of intangibles, double tax treating issues, planning, business model optimization, structuring and economic consulting.

Under his leadership, Deloitte’s regional transfer pricing practice has been consistently recognized as one of the leading practices in Latin America, including 2016 International Tax Review Americas Tax Awards Mexico Transfer Pricing Firm of the Year. He has consistently been named as one of the World’s Leading Transfer Pricing Advisors by Euromoney Legal Media Group.

His clients include several Fortune 500 multinational companies doing business in Mexico. He has extensive experience and a successful track record leading the Mexican negotiations of Advanced Pricing Agreements (APA); Mutual Agreement Procedures (MAP) and transfer pricing examinations with Mexican and foreign authorities, teaming with colleagues in Deloitte’s global transfer pricing network.



Joe Tobin

Joe Tobin   Senior Manager, Global Transfer Pricing
Deloitte

Joe Tobin is a senior manager in Global Transfer Pricing at Deloitte’s Washington National Tax Practice. He is an expert in transfer pricing controversy and transfer pricing planning, especially in the area of cost sharing arrangements. Tobin serves a wide variety of clients, specializing in intangible-centric industries such as the high-technology industry and the bio-pharmaceutical industry. He was the primary drafter of the US Treas Reg §1.482-7 (2011) Final Cost Sharing Regulations and the US Treas. Reg §1.482-7 (2013) Final Cost Sharing Regulations. Tobin was chosen by USCIB to comment on the OECD’s 2015 Discussion Draft on Cost Contribution Arrangements. He also helped the ABA and USCIB draft comments on Notice 2015-54 and the Section 367 temporary regulations and Section 482 temporary regulations released in September 2015.

Tobin was previously senior counsel at the IRS Office of Associate Chief Counsel (International) (Branch 6) (Transfer Pricing) in Washington DC, where he was a reviewer for several high profile transfer pricing litigation cases, including Veritas, Medtronic, Amazon, Microsoft, Coca-Cola, and BMC Software. He also advised IRS exam and field counsel on hundreds of contentious transfer pricing audits that went to IRS appeals. Tobin was also commented on several versions of the draft IRS Appeals Settlement Guidelines on Cost Sharing Buy-Ins, which have never been published. He was also known as the ‘go-to’ person for Advanced Pricing Agreements (APAs) with complex technical issues involving cost sharing arrangements (CSAs), and he advised on several such APAs with CSAs.



Dave Varley

Dave Varley   Principal
Deloitte

Dave Varley is a principal in Deloitte Tax’s Washington National Tax Transfer Pricing practice. He assists clients on a range of international tax subjects, focusing on transfer pricing risk management, Advance Pricing Agreements, Mutual Agreements, and related US Competent Authority matters.

Prior to joining Deloitte, Varley most recently served as the acting director, transfer pricing operations (TPO), where he was responsible for the Internal Revenue Service’s overall transfer pricing strategy, providing executive level leadership to the Advance Pricing and Mutual Agreement program and overseeing its bilateral relationships with US treaty partners. Through the field-based Transfer Pricing Practice, he was responsible for directing significant transfer pricing disputes arising in examination. As part of the Large Business & International (LB&I) senior executive team, he played a key role in redesigning how TPO and LB&I will operate in the future.



John Wells

John Wells   Principal, US Transfer Pricing Leader
Deloitte

John Wells is the mid-America leader of Deloitte Tax’s US transfer pricing practice. He is experienced in managing large projects involving quantitative analysis in the areas of transfer pricing, intangible valuation, labour reform, finance, fiscal policy and international and macro-modelling. Before joining Deloitte, Wells was the lead economist for the global energy and natural resources sector of another big four firm and an economic adviser to the Kuwait government. He also spent four years on the faculty of Auburn University, where he taught PhD-level courses in time-series analysis, macroeconomics and international finance. He has numerous publications to his name, and refereed for the American Economic Review, Economic Inquiry and other journals. Wells was awarded a National Science Foundation grant for his work on the effects of political events on financial markets.



David Forst

David Forst   Practice Group Leader - Tax
Fenwick & West

David Forst is the practice group leader of the tax group of Fenwick & West where he focuses on international corporate taxation. He is included in Euromoney Legal Media Group’s Guide to the World’s Leading Tax Advisers. He is also in Law and Business Research’s International Who’s Who of Corporate and Tax Lawyers (for the last seven years). Forst is listed in Chambers USA America’s Leading Lawyers for Business (2011-2016), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine. Forst is a lecturer at Stanford Law School on international taxation where he has taught Stanford’s international tax course for a number of years.

He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. Forst is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives’ Institute, and the International Fiscal Association.



Luis Carrillo

Jivan Datta   Director – Transfer Pricing
Bureau van Dijk

Luis Carrillo is a transfer pricing economist with over eight years of consulting experience, including Big Four firms, with focus on intangible property valuations and global transfer pricing compliance. He is responsible for developing global software solutions for transfer pricing for corporate tax departments and practitioners. Carrillo holds a BA in Economics from the University of California, Santa Cruz.



Sam Cicogna

Jivan Datta   Vice President and Head of ONESOURCE Transfer Pricing
Thomson Reuters

Sam Cicogna brings a unique perspective to his job as vice president and head of ONESOURCE Transfer Pricing for the Corporate Division of Tax and Accounting.

Prior to joining the team, he touched the Thomson Reuters product suite in various ways: as a client; steering committee member; competitor; and public accounting firm user. These prior experiences allow him to directly understand market needs and the challenges of end users interacting with the software and services on a daily basis.

Cicogna joined Thomson Reuters in 2008 when his employer was acquired to solidify the ONESOURCE product suite. Since the acquisition he has been challenged with merging diverse services teams, creating a single culture and using his experience to expand the product offering.

He holds a bachelor of science in business administration (accounting) from the University of Dayton and is a licensed Certified Public Accountant in the State of Georgia. He is a member of the AICPA and the Association for Computers & Taxation, and is based in Atlanta, Georgia.

 

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