The 14th annual International Tax Review and TPWeek Global Transfer Pricing Forum took place at the Park Hyatt Hotel in Washington DC on September 22 and 23, in association with Deloitte.
This year’s special focus included the G20 and OECD base erosion and profit shifting (BEPS) project as well as the impact on multinational taxpayers of the possible introduction of country-by-country (CbC) reporting, and the transfer pricing compliance burden this will place on them. Panel debates featured speakers from US Department of Treasury, Fiat, Nissan, Hewlett Packard, PepsiCo, Merck Group, and many more as well as top transfer pricing advisers.
Delegates heard how best to cope with the compliance burden of CbC reporting, along with how to combat new audit approaches from government. In addition, industry-specific break-out panels allowed for a more targeted approach to transfer pricing planning.
You can navigate the event pages to view the delegate list, speaker biographies and photos so you can get a sense of the scale of the forum and confirm your attendance at next year's forum.
Why tax inversions have been so prevalent in the life sciences industry
Unanswered questions on the digital economy drive scepticism over OECD's BEPS progress
Bob Stack reiterates arm's-length standard and supports need for CbCR
US Treasury official speaks out against patent boxes
For speaking enquiries contact Sophie Ashley
Tel: +44 7779 8339
For sponsorship enquiries contact Megan Poundall
Tel: + 44 7779 8325
For delegate enquiries contact Alicia Sprott
Tel: + 44 7779 8334
Agenda, Day 1 - September 22
8.30 Registration and breakfast
9.00 Chair's introduction and opening remarks
Sophie Ashley, Managing Editor, TPWeek
Todd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte
9.10 Keynote address
Sam Maruca, Former Director, Office of Transfer Pricing Operations, US Internal Revenue Service
9.30 BEPS: A general update
BEPS is still creating debate about its potential impact on taxpayers. Without final documents and guidance to react to, taxpayers are still trying to prepare for possible changes to the way they do business and are looking to review the transactions they have already put in place for possible risks to audit.
- What are the general debates that have arisen during the BEPS project in the past year?
- Recommendations for action based on new material released by the OECD and its commentators.
Tim Tuerff, Partner, Deloitte (moderator)
Roy Herzgsell, Head of Transfer Pricing, Colfax Group
Will Thompson, Director of Transfer Pricing, Brown-Forman
David Forst, Partner, Fenwick & West
11.15 Digital economy issues: Where are we heading?
The OECD has published a discussion draft on the "Tax Challenges of the Digital Economy", relating to Action 1 (address the tax challenges of the digital economy) of the action plan (AP) on base erosion and profit shifting (BEPS). This new OECD discussion draft examines the evolution over time of information and communication technology (ICT), including emerging and possible future developments.
- Discuss the spread and impact of ICT across the economy
- Share examples of new business models
- Identify key features of the digital economy
Keith Reams, Partner, Deloitte (moderator)
Paul Morton, Head of Group Tax, Reed Elsevier Group
Deborah VanHorn, Senior Director of Tax, IDT – Integrated Device Technology
Mike Bowes, Transfer Pricing Director, Deloitte
Steven Davies, Principal and BMO Leader, Deloitte
13.40 Keynote address: The future of transfer pricing documentation
Jeremy Berkovits, Senior Solution Consultant, Thomson Reuters ONESOURCE
14.00 Industry panel focus: TMT, life sciences, manufacturing
Industry expertise is becoming more and more important in the transfer pricing area. This panel will help you understand why and suggest how to address industry dynamics, competitive landscape, innovations, and disruptions in the pricing models. The industry panel will introduce you to the latest industry-specific pricing models and trends within key industry groups: Technology, media and telecommunications, energy, life sciences, manufacturing and consumer products.
Kristine Riisberg, Principal, Deloitte (moderator)
Ognian Stoichkov, Director, Global Transfer Pricing, PepsiCo
Aydin Hayri, Principal, Deloitte
Kaoru Dahm, Principal & Transfer Pricing Economist, Deloitte
15.40 Keynote address
Randall Fox, Transfer Pricing and APA Specialist, World Bank Group
16.00 Hot topics in global transfer pricing
While BEPS is holding centre stage in the global transfer pricing debate it is not the only international issue. Various regulation changes in Latin America have had an impact on how taxpayers organise their global affairs. The European Commission is also releasing new reports and launching investigations into suspected transfer pricing abuse. In Asia, China is relaxing its stance towards OECD guidelines and India released a raft of new transfer pricing measures in its 2014 budget, including acceptance of the interquartile range and use of multiple year data.
Shanto Ghosh, Partner, Deloitte (moderator)
David García Morales, International Tax Lawyer, Ecopetrol
Randall Fox, Transfer Pricing and APA Specialist, World Bank Group
Ramón López de Haro, Partner, Deloitte
17.15 Close of day one
17.30 Cocktail reception
All Global Transfer Pricing delegates and speakers are welcome to join us for drinks, canapés and networking
Agenda, Day 2 - September 23
8.30 Registration and breakfast
9.00 Chairman’s opening remarks
Ralph Cunningham, Managing Editor, International Tax Review
Todd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte
9.10 Keynote address
Robert Stack, Deputy Assistant Secretary (International Tax Affairs), US Department of Treasury
9.30 BEPS: A detailed discussion of recently released final guidance on TP documentation and countryby- country reporting
Entrenched in the BEPS debate is the concept of country-by-country (CBCR) reporting. CBCR has evolved from a fringe concept to a global reality in a relatively short space of time. It could mean that individual jurisdictions have a better idea of a company's global tax payments but it could also implicate a significant compliance burden for taxpayers if not handled correctly.
- What will it mean for multinational companies and how will it affect their transfer pricing compliance?
- Discuss the controversial aspects of CBCR whilst giving tips to taxpayers about the best ways to manage its impact on their company
Mark Nehoray, Managing Partner, Deloitte (moderator)
Sameer Chaudhary, Americas Transfer Pricing Manager, Hewlett Packard
Inga Kondrataite, Head of Transfer Pricing, AMIE (Africa, Middle East, India and Europe), Nissan
Andrew Kim, Partner, Fenwick & West
Darcy Alamuddin, Partner, Deloitte
11.15 The profit split method
While the US transfer pricing regulations refer to the "profit split method", there are two methods that fall under this heading.
This panel will focus on:
- Value creation
- Intangible issues
- Different models
- Location specific advantages
Rob Plunkett, Principal, Global & US Financial Service TP Leader, Deloitte (moderator)
Andrea Bonzano, Head of Tax, Fiat
Frank Schoeneborn, Head of Global Operational Transfer Pricing Management, Merck Group
Boris Nemirov, Tax Principal/Partner, Transfer Pricing, Deloitte
13.40 Keynote address
A step forward to mitigate Transfer Pricing risks – a global ISO certification on TP
Dr. Knut Olsen, Global Tax Practitioner & Adjunct Tax Professor, Dr. K. Olsen Global Tax Consultant
14.00 Supply chain restructuring and intangible planning in the current environment
Considering the uncertainty surrounding intangible assets, supply chain restructuring has become an even more risky business for taxpayers in recent years.
- Focus on business transformations to create entrepreneurial structures within a group of companies
- Discuss best practices and determine the different types of intellectual property a company could be dealing with
- How these different types of IP will affect restructuring
John Wells, Principal, Deloitte (moderator)
Dr Napoleão Dagnese, Head of International Tax, OC Oerlikon
Don Maher, Director of Tax Planning, The Dow Chemical Company
Michael Gilson, Partner, Deloitte
Will Thompson, Director of Transfer Pricing, Brown-Forman
15.45 Dispute resolution and controversy management: Emerging issues
Each year, more and more rulings are being made in various high courts and tax courts around the world. All of these rulings, if not binding in law outside of the particular country, have lessons for taxpayers; slowly helping to build a clearer picture about the art of transfer pricing.
- Hear from notable transfer pricing case studies
- Cover new tactics for audit defence, taking a long-term view on the risks of transfer pricing controversy
- In-house counsel will provide their first-hand experiences
Rob O'Connor, Partner, Deloitte
Katherine Amos, VP, TP Strategy, EATON
Keith Richey, International Tax Counsel, Xylem Inc
Cindy Hustad, Director, Tax Controversy Services, Deloitte
James R. Gadwood, Sullivan & Cromwell
17.00 Close of day two
|Darcy D Alamuddin|
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.
Last year Alamuddin was accepted into the IWF Leadership Foundation, which selects exceptional emerging women leaders from the corporate, government, academic, and the non-profit sectors for its acclaimed year-long Fellows Program. She was one of 35 rising women leaders from 14 nations selected, making it the largest and most competitive pool of candidates in Fellows Program history.
Alamuddin holds a BBA and JD-MBA from the University of Wisconsin-Madison.
Vice President, Transfer Pricing Strategy
Katherine Amos is the vice president, transfer pricing strategy at Eaton, a global diversified power management company. She joined Eaton in October 2013 and is responsible for global transfer pricing across all of its businesses.
Prior to joining Eaton, Amos was responsible for global transfer pricing at Tyco International from 2000 to 2013. From 1992 to 2000, she worked for E&Y and PwC in New York City as a transfer pricing consultant for companies operating in a wide variety of industries. Amos has extensive experience in transfer pricing planning, documentation, and defense, and she has been a guest speaker at both domestic and global conferences.
Sophie Ashley became the managing editor of TPWeek.com, an online transfer pricing specific publication, in 2012.
The team reports on international transfer pricing issues, sending out a bi-weekly newsletter. In addition, Ashley hosts transfer pricing events, including the Global Transfer Pricing Forum and the Asia Transfer Pricing forum.
Head of Tax
Andrea Bonzano holds a degree in economics, he has also graduated as a chartered accountant and tax expert graduation with the Italian chartered accountant association. After a starting experience as tax consultant, he entered the Fiat Group in 1990, working as tax manager for different sectors (aviation, railways equipment, general contracting, space & defence and energy). Bonzano was formerly a member of tax committees in the frame of EU industrial cooperation projects (Tornado/Euro fighter combat aircrafts, Ariannespace rocket production and launch). He was a member of several International Taxation Committees and occasionally teaches in tax training programmes sponsored by Italian Universities and tax administrations.
In 2009, Bonzano joined the European Joint Transfer Pricing Forum established by the European Commission in order to assist the Commission on transfer pricing matters. As a non-government member, he is one of the 15 EU transfer pricing experts representing the private sector within the body.
Bonzano has over 20 years of experience in transfer pricing and is EMEA operations head of tax at Fiat Chrysler Automobiles. In his role, he is directly involved in tax planning, tax controversies and manages transfer prices polices and issues deriving from a cross border flow in the range of €90 billion a year. In this role, he negotiates and is continuously negotiating several APA and has been involved in many cross border tax audits and court cases.
He speaks Italian, English and French.
National Technology Leader, US Transfer Pricing Practice
Michael Bowes is Deloitte's National Technology leader for the US transfer pricing practice. He has more than 14 years' experience consulting on transfer pricing and tax issues for several of the world's largest technology companies. He provides valuation and economic consulting services involving mergers and acquisitions, international tax planning, and the restructuring and reorganisation of international operations. He has negotiated US and foreign Advanced Pricing Agreements, managed US and foreign transfer pricing audits, and met with various competent authorities on behalf of his clients.
Bowes directs a team of over 25 transfer pricing analysts across the Pacific Northwest from his offices in San Jose, California and Portland, Oregon.
Prior to joining Deloitte Tax, Bowes was an economist with another big four firm, an economist with Christensen Associates, and a graduate teaching fellow in the economics department of the University of Oregon.
Americas Transfer Pricing Manager
Ralph Cunningham became managing editor of International Tax Review, which covers cross-border corporate tax issues for multinational companies, in November 2003.
Cunningham and an editorial team of six are responsible for the content of International Tax Review, which includes: a magazine that comes out 10 times a year; websites (www.internationaltaxreview.com, www.tpweek.com and www.itrpremium.com); supplements; and other products, such as awards and the annual World Tax and World Transfer Pricing directories.
He also hosts events on behalf of the publication such as the Global Transfer Pricing Forum, which has been running for more than 10 years; the Asia Tax Executives' Forum; and the India Tax Forum. He has also moderated the successful series of web seminars the magazine has run since 2007.
|Dr Napoleão Dagnese|
Head of International Tax
|James R Gadwood|
|Kaoru K Dahm, Ph.D|
Kaoru K Dahm, Ph.D, is a principal in Deloitte Tax's National Tax Office in Washington DC. At Deloitte, Dahm is a Global Tax & Legal Manufacturing Industry Leader, as well as a co-leader of US Transfer Pricing Team Automotive Industry Group. Dahm is also a US leader of Deloitte Japanese Services Group Transfer Pricing Network. She has undertaken and supervised transfer pricing studies for advance pricing agreements (APAs), tax planning and corporate restructurings, cost sharing arrangements, intangible valuation, transfer pricing compliance and documentation, headquarters cost allocation, transfer pricing audit support, and other projects for a variety of industries. These industries include: pharmaceuticals; chemicals; biotech; e-commerce; medical equipment; automobiles and automobile parts; computer software; industrial machinery; construction equipment; energy; and semiconductors. While at Cal-Tech, Dahm designed and wrote computer programmes to simulate stochastic processes in financial studies and conducted numerous computerised experiments in the field of economics and finance.
Dahm has been recognised as one of the world's leading transfer pricing advisors in Euromoney's "Expert Guide to the World's Leading Transfer Pricing Advisers" and in "Expert Guide to the World's Leading Women in Business Law: Transfer Pricing." Her publications (with co-author(s)) in professional journals include "New Services and Intangibles Regulations: IRS Changes the Mix" in Tax Management Transfer Pricing Report (August 16, 2006), which was also published in Tax Management International Journal (Vol. 35, No. 11, 11/10/2006); "A Framework for Analysing Transfer Pricing under U.S. FIN 48" in International Taxation (Vol. 28, September 2008); "Is It Time to Revisit Transfer Pricing Planning?" in Tax Notes International (March 8, 2010); and "Similarities and Differences in U.S. and Japanese Transfer Pricing Documentations" in Kokuzei Sokuho (June 10, 2011). Dahm is a frequent speaker at business and professional conferences.
|David L Forst|
David L Forst is the practice group leader of the tax group of Fenwick & West. He is included in Legal Media Group's Guide to the World's Leading Tax Advisers. He is also included in Law and Business Research's International Who's Who of Corporate Tax Lawyers (for the last six years). Forst was named one of the top tax advisers in the western US by the International Tax Review, is listed in Chambers USA America's Leading Lawyers for Business (2011-2014), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.
His practice focuses on international corporate and partnership taxation and he is a lecturer at Stanford Law School on international taxation. Forst 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.
Forst graduated with an AB, cum laude, Phi Beta Kappa, from Princeton University's Woodrow Wilson School of Public and International Affairs, and received his JD, with distinction, from Stanford Law School.
Transfer Pricing & APA Specialist
Randall Fox provides technical assistance on transfer pricing and APA matters to World Bank Group member countries around the world. He has developed and executed on-the-ground capacity building workshops on technical transfer pricing and APA matters in numerous countries. He has also assisted with the drafting of transfer pricing guidelines and APA procedures, and is currently helping establish several APA programs around the world.
Before joining the World Bank Group, Fox was an APMA team leader with the IRS who resolved MAP and APA cases with numerous countries, and was responsible for coordinating all cases between the US and Switzerland. He has also spent time in the private sector with both Duff & Phelps and Ernst & Young, focusing on transfer pricing.
|David Garcia Morales|
International Tax Lawyer
|Dr Shanto Ghosh, Ph.D|
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 has also been a visiting lecturer at the IBFD Netherlands and is a member of International Taxation magazine's editorial board. 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.
In addition to his consulting experience, Ghosh is a visiting lecturer at Brandeis University and has been a teaching fellow at the Harvard Institute of International Development and a lecturer of Financial and Development Economics at the University of California, Berkeley.
Over the last 17 years Michael Gilson has helped many clients in the manufacturing, consumer products, and services industries realign their value chain (marketing, sales, supply chain, procurement, manufacturing, quality) in both Europe and Asia. He has done this by designing and implementing business model optimisation methodologies involving the creation of tax efficient structures utilising principal or central entrepreneur companies based in Switzerland, Ireland, Singapore and other jurisdictions. These tax efficient structures typically involve the conversion of local sales companies into limited risk distributors, and buy-sell manufacturing companies into toll or contract manufacturers operating under the direction of the European or Asian principal company.
Many of these projects involved analysing the tax efficiency of locations to hold the company's intellectual property (IP) and structuring the transfer of such IP.
Aydin Hayri is a transfer pricing principal (partner), life sciences industry leader, and also manages the Deloitte Greater Washington DC and Philadelphia transfer pricing groups.
Since 1998, he has assisted clients with tax planning for IP, IP development, cost sharing, and licensing strategies; and planning and implementation of supply chain and business model restructurings. Besides the life sciences industry, his experience covers defense/aerospace, and high-technology manufacturing, and software industries.
Hayri has provided thought-leadership by developing and applying sourcing strategies, as well as, adjustments for economic downturns. Aydin recently published a highly accessible book, Transfer Pricing in Action, sharing his experiences in a business-novel, case study format.
Before joining Deloitte, Hayri was an assistant professor of economics at Charles University, Prague; the University of Warwick, England; and a research fellow at Princeton University. Hayri still teaches occasional courses for MBA students. He is also an artist, his work can be viewed at www.aydinhayri.com
Ph.D, and MA, economics, Princeton University
BA, economics, Bogazici University, Istanbul
Selected Transfer Pricing Publications:
"Frontiers of Transfer Pricing in Life Sciences," ITR 2015 Special Issue, with Keith Reams.
"Indicia of Economic Ownership," ITR 2014 Special Issue, with Darcy Alamuddin.
Transfer Pricing in Action, Kluwer Law, with Althea Azeff, July 2013
"Intellectual Property Planning for Startups," ITR 2012 Special Issue," with James Gannon, Dec. 2012.
"The Branded Prescription Drug Annual Fee and Transfer Pricing," 21 Transfer Pricing Report 339, with George Soba and Alan Shapiro, July 2012.
"Is it Time to Revisit Transfer Pricing? Economic Downturn and Transfer Pricing" with Kaoru Dahm, Tax Notes International, March 2010
"Neither a Distributor Nor a Commissionaire: Benchmark Returns for Low-Risk Distributors," with Michael Aarstol, Transfer Pricing Report, July 2003.
"Firm Profitability in Recessions," with Dick Clark, Transfer Pricing Report, BNA, May 1, 2002 and March 6, 2002.
Head of Transfer Pricing
Director, Tax Controversy Services
Cindy Hustad is the west region tax controversy competency leader for Deloitte and represents corporate clients before the IRS. During her 15-year tenure at Deloitte, she has successfully represented many large and small clients, both at the examination and appeals levels, specialising in transfer pricing and international issues. Prior to joining Deloitte, Hustad was a special trial attorney with the IRS Chief Counsel's Office where she represented the IRS in US Tax Court in over 50 litigated cases. During her period at the IRS, Hustad also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. She also represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v Commissioner.
Hustad holds a BA from the University of Wisconsin, a JD from the University of Wisconsin Law School, and a LLM (Tax) from New York University Law School.
|Andrew J Kim|
Andrew Kim is a partner in the tax group of Fenwick & West. His practice focuses on both domestic and international corporate tax matters, with an emphasis on tax dispute matters. Kim served as counsel in the recent case, CBS Corporation v United States in the US Court of Federal Claims, and currently serves as counsel in Analog Devices, Inc. v Commissioner in the US Tax Court.
Kim has significant experience in representing clients with respect to cross-border transactions, corporate restructurings, international joint ventures, transfer pricing, as well as dispute resolution matters. He has published articles on international tax issues and developments in the Journal of Taxation, International Taxation, the Euromoney Corporate Tax Handbook, and World Tax. Kim frequently speaks on international tax issues at meetings for professional tax groups, including the Tax Executives Institute and Bloomberg BNA.
Kim was included by Euromoney among the World's Leading Tax Advisors (2014), and Tax Controversy Leaders (2014).
Fenwick's tax practice has earned a reputation as one of the nation's leading domestic and international tax practices. International Tax Review recognised Fenwick in its first tier in both its World's Leading Tax Planning Firms and World's Leading Transactional Firms guides in 2014. Fenwick was also recognised by International Tax Review as US Tax Litigation Firm of the Year in three different years, and Americas M&A Tax Firm of the Year.
Kim received his JD, cum laude, from Harvard Law School, and BS in Psychology with highest honors from the University of Illinois.
He is a member of the State Bars of California and Illinois.
Head of Transfer Pricing AMIE
Former Director of Transfer Pricing Operations
Samuel Maruca was the first director of Transfer Pricing Operations for the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) from May 2011 until August 2014. In that position, he was responsible for the development and coordination of LB&I's overall transfer pricing strategy and resourcing. He had jurisdiction over the Advance Pricing and Mutual Agreement programme and provided direction on significant transfer pricing disputes arising in examination.
Maruca has been in private practice in the federal income tax field in Washington, DC since 1982. For the past 20 years, he has specialised in large-case dispute resolution, focusing primarily in the international tax and transfer pricing areas. During his career, he has successfully resolved many complex and contentious cases, at the audit level, in appeals, in competent authority, in the APA program, and in the courts. These matters have arisen in a broad range of industries, including: pharmaceuticals; information technology; communications; media and entertainment; homebuilding; specialty materials; and retail.
|Donald J Maher|
Director of Tax Planning
Donald J Maher is senior tax counsel at The Dow Chemical Company in Midland, Michigan. His experience principally relates to international transactions, cross-border acquisition and disposition planning, and general tax rate reduction planning.
Prior to joining Dow in 2007, Maher worked at Koch Industries where he served as an attorney-advisor to several Koch businesses. Further, prior to joining Koch, Maher spent several years in public accounting working for KPMG and Deloitte and focused on the design and implementation of income shifting strategies, including the design of transactions and legal structure for large US-based multinational technology enterprises. Maher is originally from Phoenix, Arizona and attended college at Creighton University. After college, he received an MBA from Thunderbird, a JD from the University of Pacific, and an LLM in Taxation from Georgetown University. He is admitted to practice law in Michigan.
Head of Group Tax
Paul Morton is head of group tax at Reed Elsevier Group. He leads a team of tax professionals in the UK, US, Netherlands and Singapore, which serves businesses operating in more than 90 countries. Reed Elsevier is a leading provider of professional information solutions including LexisNexis and the Elsevier Science, Technology and Medical publishing divisions. Prior to joining Reed Elsevier, Morton led the tax team for Royal Dutch Shell's global marketing and refining division. He held a number of positions before that at Shell including European internal audit manager, head of tax for Shell UK and advisor to the exploration and production businesses. Prior to that he was a tax manager at KMPG and he began his career as a tax inspector in the Inland Revenue.
Morton is chairman of the British Branch of the International Fiscal Association, a member of the Business & Industry Advisory Committee which provides input to the OECD and a vice chair of the ICC Taxation Commission as well as a member of various UK industry and professional tax bodies.
Mark Nehoray is a senior partner in the Los Angeles office of Deloitte Tax. He has been consistently recognised by International Tax Review as one of the leading transfer pricing advisers in the United States and by Euromoney Legal Media Group as one of The World's Leading Transfer Pricing Advisers.
Nehoray has over 33 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas. He consults with multinational clients on trans-border transactions, assists multinational companies with transfer pricing studies, and consults with clients on restructuring of foreign royalties and other foreign income streams.
Mr. Nehoray is the transfer pricing advisor to three of the world's largest multinationals, and over the past 24 years has conducted a significant number of transfer pricing studies in a variety of industries (for example: entertainment and media; gaming; multi-level marketing; consumer products; e-commerce; and non-profit). These projects have included both defensive work with respect to on-going IRS audits, and competent authority assistance, as well as planning studies and APAs. Some of these projects have involved the restructuring of a US company to minimise US federal, state and foreign income taxes and US and foreign customs duties.
Since 2002, Nehoray has been the executive producer and the host of Deloitte's Transfer Pricing Dbriefs, a monthly Internet programme. He has serves as a transfer pricing instructor at the firm's various national and international tax training programs.
Nehoray's recent publications include:
Boris Nemirov is a tax principal in the New York office of Deloitte Tax's transfer pricing group. His experience includes over 15 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 worked on a number of business model optimisation, restructuring and intellectual property projects, involving the valuation of intangible assets, derivation of platform contributions and development of royalty rates. Nemirov has also consulted and defended under audit numerous clients on headquarters cost allocation issues. His experience includes negotiating bilateral advance pricing agreements involving the tax authorities in the United States, Canada and Japan. Furthermore, Nemirov specialises in financial transactions transfer pricing focusing on intercompany factoring, financing, risk transfers, guarantees and cash pooling arrangements. He also leads numerous global transfer pricing documentation engagements for multinational clients.
Nemirov has significant experience in dealing with transfer pricing issues impacting multinationals, covering tangible, service, intangible and financial transactions. In recent years, he worked on several planning engagements aimed at optimising and streamlining, from a tax and transfer pricing perspectives, business changes and cost-cutting initiatives of several multinational giants. Nemirov has also led engagements for multinational companies with the objective of optimising the intellectual property ownership structure for better alignment with business objectives and natural organic growth of the organisations.
Nemirov is the US Transfer Pricing Technology Leader and spearheads the Operational Transfer Pricing and Data Analytics initiatives partnering with the Tax Management Consulting Group to deliver these cutting edge solutions to clients. Over the past six years, he was heavily involved as a subject matter expert in, and now globally leads, a project to design the next generation transfer pricing modeling and reporting software that has already been successfully used by the group worldwide for the past three years. He is also responsible for managing all software and databases utilised by the US transfer pricing practice. Nemirov is a Deloitte Faculty Excellence certified facilitator and has, for the past eight years, actively participated in and served as the Dean of a multitude of national training programs. Finally, he is a frequent speaker at the Tax Executives Institute events and numerous Deloitte internal and external conferences. Nemirov also actively participates in numerous national initiatives, including those aimed at Deloitte Tax's response to BEPS and was nominated to appear in the 2013 Guide to the World's Leading Transfer Pricing Advisers, which will be released in September 2014.
Nemirov holds a BA in economics and an MBA in finance & accounting.
Leader, Transfer Pricing & Competent Authority Group
|Dr Knut Olsen|
Global Tax Practitioner & Adjunct Tax Professor
Knut Olsen has more than 30 years' experience within taxation and has specialised in international taxation inclusive transfer pricing, global tax risks and ISO certification on global tax. He is also an ISO 9001 Quality Lead Auditor, cooperates with Intertek (Moody International), and supports multinational corporations with ISO certification on: transfer pricing; global tax risks; and anti-corruption.
Olsen has a background as head of global tax & legal in several multinational corporations and adjunct tax professor at Thomas Jefferson University where he has been lecturing in transfer pricing risks, global tax risk management, advanced global tax planning and EU & taxation.
Olsen has two master degrees and a PhD in international taxation in additional to education within law, finance, economic, accounting and risk management. His PhD thesis Characterisation and Taxation of Cross-Border Pipelines was published by IBFD in 2012.
Principal, Global & US Financial Service Transfer Leader
Robert Plunkett is the managing principal of Deloitte Tax's Northeast transfer pricing group. In addition, he leads the firm's financial services transfer pricing practice.
Plunkett has provided services to 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, Plunkett has worked on contemporaneous documentation, planning, audit defense, and advance pricing arrangements.
Some of the banking projects on which he has worked have involved income and expense allocation among branches for activities ranging from global trading to provision of ancillary and/or support services. His investment banking experience includes analysis of global trading of derivatives, merger and acquisition activity, loan syndication, and prime brokerage. In global trading transactions, Plunkett has helped to price the assumption of market risk, the assumption of credit risk, the performance of trading functions, and the provision of sales and/or marketing services. He has assisted insurance companies in pricing the transfer of risk among entities, and insurance brokerages in allocating income and expense from global placements. Plunkett has worked on a number of investment advisory projects, including the pricing of advisory functions, sub-advisory functions, custody functions, and brokerage functions for both traditional and alternative investment managers.
Plunkett has also spent a considerable amount of time on the pricing of intercompany lending, the pricing of intercompany guarantees, and the pricing of various intangible assets and intangible asset transfers.
Keith Reams is the US and global leader for clients and markets for Deloitte's global transfer pricing services practice. He has advised clients around the globe on intercompany pricing transactions with respect to income tax regulations in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Columbia, Czech Republic, Denmark, France, Germany, India, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia, Mexico, the Netherlands, Norway, Peru, Poland, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, the United Kingdom, and the United States. He has assisted numerous multinational companies with international valuation and economic consulting services involving merger and acquisition activity, international tax planning, and restructuring and reorganisation of international operations.
Reams is on the global tax management team for Deloitte's technology, media, and telecommunications practice and is a leader in the area of transfer pricing for newly emerging industries, such as electronic commerce and cloud computing, where he has extensive experience around the world in helping clients extend their business models into new territories.
Reams has testified as a qualified expert in numerous valuation and transfer pricing disputes, including the cases of: Nestle Holdings Inc v Commissioner; DHL Corp v Commissioner; and United Parcel Service of America, Inc v Commissioner. In addition, he is one of only three economists in the United States approved by the New York State Department of Taxation and Finance to provide transfer pricing expertise and testimony in cases involving cross-border transactions within commonly controlled affiliated groups. He has also helped many clients to successfully resolve valuation and transfer pricing disputes before they reach trial.
Reams completed course requirements for a Ph.D in international finance from New York University. He holds a master of arts in economics from California State University Sacramento and a bachelor of science in chemical engineering from Stanford University.
International Tax Counsel
Keith Richey is an international tax attorney with over 30 years of experience serving major US multinational companies. He is known for devising and implementing major tax planning initiatives, understanding complex legal issues and his ability to translate them into plain English, business sensitivity and knack for quickly developing workable tax optimised solutions, proven ability to manage large long-term projects, and knowledge of transfer pricing, APB23/ASC 740-30 and FIN 48/FAS 109/ASC 740-10, plus, of course, US and major foreign tax laws, particularly key drivers for tax savings.
Richey is the international tax counsel for Xylem, a leading global water technology provider that was recently spun-off from ITT Corporation. Previously, he was international tax counsel for ITT Corporation, and before that: director international taxes for Xerox Corporation; senior international tax counsel for Citicorp (Citibank); tax counsel for Mobil Oil; senior tax attorney at Exxon; and summer clerk at Gibson Dunn & Crutcher.
Richey is the vice president in charge of the Westchester County, New York & Connecticut Region of the USA Branch of the International Fiscal Association. He was co-author of "Managing the debt/equity structures of a multinational", published in The Treasurer; sole author of "Privatization and Debt-for-Equity Swaps", published in three legal journals: The International Tax Journal, The Journal of Bank Taxation, and The Banking Law Journal; and "Allocating Interest and Other Expenses under Code section 864(e)", The Tax Executive.
He holds: a JD from the University of Texas at Austin Law School, where he received the American Jurisprudence award for Constitution Law; an LLM from New York University; and a BS cum laude from the University of Southern California.
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. Her work has been in the following industries: media and entertainment; publishing; telecommunications; digital; computer software; semiconductors; consumer goods; high-end luxury good;, oil and gas upstream and field services sectors; power generation and renewable energy; chemical industries; healthcare and medical; commodities; financial services; automotive and automotive suppliers; quick service restaurants; and travel.
Riisberg has an international background and experience working in Deloitte transfer pricing teams in Copenhagen and London build 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.
Riisberg has given numerous speeches and presentations at the American Conference Institute, Tax Executives Institute, BNA, Atlas, Thompson Reuters, CITE, Deloitte Debriefs and Conferences on transfer pricing issues. Recent speaking engagements include: Deloitte Tax's global US investment services and transfer pricing group, Intangible Property Migration, Stockholm (April 2014), OECD's Discussion Draft on Intangibles, Deloitte's Global Tax Planning Conference EMEA, High-Tech Luncheon, Barcelona (June 2012), US Tax issues for Swedish groups, Deloitte Tax's global US investment services and transfer pricing group, Stockholm (June 2012), Globalization, Transfer Pricing and Tax Planning, Oracle Corporation, at George Mason University, Washington DC (October 2011), Current Developments in the Use of Federal Tax Incentives and other Tax & Accounting Topics in the Film Industry, BNA/Atlas 11th Annual New York International Film & TV Finance Summit (September 2011), International Financial Reporting Standards: Is Conversion An Issue for Transfer Pricing?, Deloitte Debriefs, Webinar (March 2011), Convergence/Conversion: Where we are and Where we are Going US GAAP to IFRS Conversion, TEI/Thomson Reuters, Webinar (July 2010),Global Transfer Pricing, To be Audited or Not to be Audited? Reducing the likelihood of Contentious Audits and Resolving Them When They do Occur, American Council Institute, New York City (March 2009), and 2006 Temporary Regulations for Intercompany Services, CITE, Washington D.C. (April 2007). Riisberg received the CITE Outstanding Star Speaker Award in January, 2008. US Transfer Pricing Planning & Controversies, Intercompany Tax Planning for Services, and The Role of Transfer Pricing in Preparing Financial Statements, FIN 48 and FAS 109.
Prior to joining Deloitte, Riisberg was an international tax manager at Andersen's Copenhagen office. Before joining Andersen, she worked at the European Commission in Brussels in the Cabinet of the Danish Commissioner for Energy and Nuclear Safety.
Riisberg's publications include "Industry Guide" in International Tax Review, September, 2014; "Intangible Property Guide" in International Tax Review, January 23, 2014, "Technology, Media and Telecoms Guide" in International Tax Review, No. 82, September 10, 2013, "Transfer pricing implications of the transition to IFRS" in International Tax Review, October 29, 2012, "US Implementation of IFRS: Impact on Transfer Pricing" in BNA Transfer Pricing Journal, 2009, VOL. 18, No. 8, and "Differences in European and US GAAP: Implications for Transfer Pricing Analysis" in BNA Transfer Pricing Journal, 2004, VOL. 13, No. 13.
Senior Solution Consultant
Tracey Rossow serves as a senior solutions consultant for ONESOURCE Operational Transfer Pricing. She works to develop the operational transfer pricing business within Thomson Reuters, working closely with clients to develop the appropriate project plans and assist in the implementation of new processes to absorb the technological changes within their organisation.
Prior to joining Thomson Reuters, Rossow's career included over 10 years in public accounting at PricewaterhouseCoopers and Ernst & Young, providing advisory and consulting services to Fortune 100 companies in the areas of tax minimisation, tax department automation and Sarbanes-Oxley 404 process controls, documentation, and risk identification and mitigation.
Rossow is a frequent speaker at transfer pricing conferences and seminars in the USA and globally. She graduated from George Washington University with a BA, and with a JD cum laude from New York Law School. She has served as adjunct faculty for the masters in tax programme at Fairleigh Dickinson University.
|Robert B. Stack|
Deputy Assistant Secretary – International Tax Affairs
Bob Stack is the deputy assistant secretary for international tax affairs in the Office of Tax Policy at the US Department of the Treasury. In this capacity, he is responsible, on behalf of the assistant secretary, for the conduct of legal and economic aspects of tax policy relative to the representation of the United States in bilateral and multilateral relations with other countries. In addition, he is responsible for advising the legal and economic staffs within the Office of Tax Policy, other offices of the Treasury Department and other government agencies as to policy analysis and interpretation for domestic legislation and administrative guidance in all matters involving cross border taxation. Stack serves as the US delegate to the Committee on Fiscal Affairs (CFA) in the Organization for Economic Cooperation and Development (the OECD). In addition, Stack oversees the Office of Tax Policy's participation in the various working bodies of the CFA and sits on the CFA Bureau (the CFA's governing body). He also serves as the US delegate to the Global Forum on Transparency.
Prior to joining Treasury, Stack served as head of the international tax practice group at the law firm of Ivins Phillips & Barker. In the private sector, he has over 26 years of experience in international tax matters, representing both corporations and individuals. His work for corporations has included structuring both inbound and outbound ventures, the establishment of efficient cross border structures, the formation of joint ventures and private equity funds and all aspects of international mergers and acquisitions.
He is a member of the American Bar Association Tax Section, New York State Bar Association Tax Section, and International Fiscal Association. Stack has participated in numerous panels on international tax issues at the meetings of the American Bar Association Tax Section as well as the Federal Bar Association. He graduated from Georgetown University Law Center in 1984, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.
Head of Global Operational Transfer Pricing Management
Dr Frank Schoeneborn is head of the global operational transfer pricing management for the German-headquartered Merck Group and has held this position for more than three years. The department belongs to the finance function of the group and is responsible for the operational implementation and supervision of transfer prices worldwide covering all divisions and subsidiaries in accordance with the guidelines set by the corporate tax department.
Prior to this position, he was the head of divisional finance for the life science chemicals division from 2008 to 2010. Previously, Schoeneborn was leading the divisional finance for liquid crystals division 2005 when he joined Merck. In these roles, he had full financial responsibility for the respective global division, provided financial decision support on a wide scope of operational and strategic matters. He managed financial reporting and forecasting, business analysis, scenario planning and acquisition integration as well as the dedicated financial reporting on transfer pricing.
Director, Global Transfer Pricing
Director of Transfer Pricing
T Timothy Tuerff is the managing partner of the Washington National Tax Office of Deloitte Tax. In this role, he leads the Washington national tax practice in providing tax analysis to clients engaged in multinational corporate and investment transactions. The professionals of this office analyse issues and transactions with respect to specific client matters as well as review current tax developments and their impact on Deloitte clients. Tuerff also serves as a member of the board of directors of Deloitte.
Tuerff specialises in international tax issues and serves US-based multinational corporate clients engaged in cross-border transactions. His practice involves tax analysis related to structuring international business operations, mergers and acquisitions, financing, and utilisation of foreign tax credits. He testified before the US Congress Ways and Means Subcommittee on Select Revenue Measures concerning Chairman Camp's 2011 International Tax Reform Discussion Draft addressing a territorial system of taxation.
Tuerff formerly served as special assistant to the chief counsel and special assistant to the associate chief counsel (international) of the Internal Revenue Service. He is a frequent contributor to tax periodicals, including: Tax Notes and Tax Notes International and the Practicing Law Institute journal Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances; the American Bar Association, International Franchising Journal; and the BNA Tax Management Portfolio, Outbound Tax Planning for US Multinational Corporations, No.6380. Tuerff is also a frequent speaker at seminars on international tax issues addressing such groups as Tax Executives Institute, International Fiscal Association, and the Tax Council Policy Institute Symposium. He currently serves on the advisory board for the Internal Revenue Service – George Washington University International Tax Symposium
Tuerff is a graduate of Indiana University School of Law and School of Business. He is a member of the American Bar Association and the District of Columbia Bar Association and is a District of Columbia certified public accountant.
|Deborah Van Horn|
Senior Director of Tax
US & Global Managing Tax Partner
Todd Wolosoff is the US and global managing tax partner for Deloitte's transfer pricing practice. He has been a tax partner in the New York City office of Deloitte for the last 25 years. He has extensive experience representing multinational companies in a wide variety of transfer pricing matters.
Wolosoff was the founding partner of the northeast transfer pricing group in 1990. He was a founding member of the national transfer pricing leadership group and has been in a leadership role for Deloitte in the transfer pricing area for more than 20 years.
Wolosoff has provided transfer pricing advice to many of the world's largest multinationals. He has conducted transfer pricing planning and documentation studies for both inbound and outbound taxpayers in virtually all industries, with a particular focus on: consumer products; life science and pharmaceuticals; electronics; automobile and automotive parts; medical products; chemicals; cosmetics; trading companies; and financial services.
Wolosoff is one of Deloitte's leading specialists in transfer pricing controversy, directing audit teams that have negotiated successful settlements in more than 50 audit controversies. He has been involved in a number of ground-breaking audit cases and has led many of the largest transfer pricing audit engagements conducted by the firm in the US. He has also participated in transfer pricing audits in Canada, France, Italy, United Kingdom, and Japan. For the past decade, Wolosoff has led Deloitte's highly attended annual webcast on strategic planning for transfer pricing controversy.
Wolosoff has been recognised every year by Euromoney as one of the world's leading transfer pricing advisors since the guide's inception in 1999. International Tax Review awarded Deloitte the North America Transfer Pricing Firm of the Year, as well as New York Transfer Pricing Firms of the Year 2011-2012. Wolosoff has been recognised by Mondaq as one of the world's leading tax attorneys.
Park Hyatt Washington DC
1201 24th St NW
Washington, DC 20037
Special room rates are available for attending delegates for September 21-22 2014 from USD319 + tax per night.
*Please note that all delegates are responsible for their own accommodation and travel.
For speaking enquiries contact Sophie Ashley
Tel: +44 7779 8339
For sponsorship enquiries contact Megan Poundall
Tel: + 44 7779 8325
For delegate enquiries contact Alicia Sprott
Tel: + 44 7779 8334