Global Transfer Pricing Forum - New York 2016

Overview

 

2016 saw the 16th year of the Global Transfer Pricing Forum take place in New York on 22 & 23 September 2016, in association with Deloitte.

The Forum hosted senior economic analysts including Alan Krueger of Princeton University and Stephen Moore of The Heritage Foundation as well as views from Edward Kleinbard from USC's Gould School of Law and John Hughes of the IRS.

Following a recent change from the typical educational-style seminar, the Forum focused on facilitating free and transparent debate on topics such as the meaning of value creation in the BEPS context, the rise in TP disputes and what revenue authorities can do now and in the future. As such, taxpayers were invited to openly share experiences of how to deal with a global transfer pricing environment that is changing rapidly.

Using an intuitive polling system, delegates were asked to share their views and opinions on the topical issues facing taxpayers today:

  • 48% of delegates polled believe that potential misinterpretation by countries with different methods or standard will be the biggest concern for multinationals
  • Interestingly, 56% of respondents are not optimistic about effective dispute resolution with only 16% having a positive outlook
  • Following the Japan/Asia-Pacific panel, 79% of delegates believe that Singapore has the most welcoming tax system
  • Technology integration with BEPS is still a concern for taxpayers with 47% concerned that integrating new technology with existing systems will be the biggest challenge

 

Transfer Pricing Forum  

EVENT FEEDBACK

"The [Global] Transfer Pricing Forum brings to light the most pressing issues that tax payers and practitioners are currently facing."

"Speakers were amazing..." with "...practical aspects from companies. Overall a great programme."

"The financial services panel was a highlight of the day"

"The event is current, asks and answers the right questions and had a great format [polling system] to present delegates' opinions and views. Brilliant all round."


FUTURE EVENTS

---------------------

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 

 


 

Agenda

Download the brochure

Day one │ 22 September


08.30 Registration and breakfast

09.00 Chair's introduction and opening remarks

Caroline Byrne, Managing Editor, TPWeek & International Tax Review
Todd Wolosoff,
Global Transfer Pricing Leader, Deloitte

09.10 Keynote address

Edward Kleinbard, Ivadelle and Theodore Johnson Professor of Law and Business, University of Southern California’s Gould School of Law

09.30 BEPS documentation strategy: An update on CbC and Masterfile/local file strategies

As the implementation of CbC rules and masterfile/local file documentation gets closer to being a reality, taxpayers are facing significant changes in reporting and documentation that raises many strategic considerations. This panel will discuss the latest developments in CbC reporting and global documentation and discuss emerging best practices to deal with them.

Moderator: Mark Nehoray, Partner, Deloitte
William Morris, Director, Global Tax Policy, GE
Eduardo Goldszal , Finance Senior Director and Head of Transfer Pricing, NCR Corporation
António Calisto Pato,
Global Head of Tax, Chiquita Brands International
Eva Parenti, Principal, Deloitte

10.45 Coffee break and networking

11.15 Technology responses to BEPS

New documentation requirements related to BEPS have required both companies and authorities to adapt their systems to manage the extra information-processing. On top of this, the emphasis on making tax data more transparent requires further technology considerations. This panel will focus on how technology is becoming more important in the transfer pricing area and how you should use it.

Moderator: Boris Nemirov, Partner, Deloitte
Shyamli Mohamed
, Director Tax, Global Transfer Pricing, Halliburton
Sam Cicogna, Vice President, Head of ONESOURCE Transfer Pricing, Thomson Reuters
James Wiley
, Director, Transfer Pricing, Thomson Reuters
Bob Norton,
Tax Specialist Leader, Deloitte

12.30 Lunch and networking

13.40 Industry panel: Financial services

The rules that have come out of BEPS implementation have affected the financial services differently to other industries. This panel focuses on BEPS guidance impacting the financial services industries, gaps in guidance, and issues involving financial transactions that are relevant in all industries.

Moderator: Robert Plunkett, Principal, Deloitte
Marcelo Vicentini, Head of Tax, Standard Chartered Bank (Brazil)
Nick Leak,
Transfer Pricing Lead, Royal Dutch Shell
Lucia Fedina,
Director, Transfer Pricing, Deutsche Bank
Ivan Mullinax, Managing Director, Deloitte

14.55 Coffee break and networking

15.25 Keynote address

Stephen Moore, Distinguished Visiting Fellow, Project for Economic Growth, The Heritage Foundation

15.45 BEPS update: PE, supply chain and allocation of risk

This panel will focus on the latest developments involving BEPS including the important topics of permanent establishments, supply chain planning and the role of intercompany agreements in future transfer pricing planning.

Moderator: Dave Varley, Principal, Deloitte
Carolina Graterol, Global Head of Tax and Transfer Pricing, Rosen Group
Jonathan Silver,
Managing Director, Head of Tax Counsel and Advisory, Jefferies
Mark Carrillo,
Director of Corporate Taxation, Ixia
Jivan Datta, Principal, Deloitte

17.00 Close of day one and WeiserMazars cocktail reception


Day two │ 23 September


08.30 Registration and breakfast

09.00 Chair's introduction and opening remarks

Caroline Byrne, Managing Editor, TPWeek & International Tax Review
Todd Wolosoff,
Global Transfer Pricing Leader, Deloitte

09.10 Keynote address

Alan Krueger, Bendheim Professor of Economics and Public Affairs, Princeton University

09.30 Updates in dispute resolution

The desire by most big economies to protect their revenue base seems to be increasing aggressively. One of the seemingly inevitable outcomes of the BEPS process will be an increase in worldwide transfer pricing controversy. This panel will focus on the hottest issues in transfer pricing controversy and discuss relevant strategies for controversy management and dispute resolution.

Moderator: Keith Reams, Principal, Deloitte
Bradley Shumaker, Tax Counsel, Transfer Pricing, Zimmer Biomet
Clay Ayers,
Director, Head of Tax, K2M
Rebel Curd, Vice President, Practice Leader of Transfer Pricing, Charles River Associates
Kerwin Chung, Principal, Deloitte

10.45 Coffee break and networking

11.15 BEPS update: IP planning and profit split strategies

This panel will review the latest BEPS guidance on IP issues and on-going projects involving this critical area. The panel will also discuss the latest thinking on the profit split method which is likely to apply more frequently in the future.

Moderator: Aydin Hayri, Principal, Deloitte
Ognian Stoichkov, Global Transfer Pricing Director, PepsiCo
Keith Richey, International Tax Counsel, Xylem
David Forst, Partner, Practice Group Leader - Tax, Fenwick & West
Philippe Penelle, Principal, Deloitte

12.30 Lunch and networking

13.40 Keynote address

John Hughes, Acting Director, APMA Program, Internal Revenue Service

14.00 Japan/Asia-Pacific

Japan accounted for the majority of APAs signed with the US last year. This is also true for many other large countries. India currently accounts for more transfer pricing initiated adjustments than any other country. China is becoming more of an important factor in the transfer pricing area. This panel will focus on recent transfer pricing developments in Japan, India and China and discuss how you can best prepare for dealing with these critical countries.

Moderator: Paul Riley, Partner, Deloitte
Abhishek Chawla,
Tax Director, Asia & Pacific, Xerox
Erin Stuart-Cayot,
Vice President, Global Tax, Fortinet
Keith Brockman,
former EMEA Tax Director, Mars
Kaoru Dahm, Principal, Deloitte

15.15 Coffee break and networking

15.45 Digital economy

The digital economy has expanded exponentially in recent years as businesses develop with technology and the global market place. Action 1 of the BEPS action plan focuses on this issue, but it is also linked to permanent establishment issues, updates to the TP guidelines and controlled foreign company rules.

Moderator: Kristine Riisberg, Partner, Deloitte
David Campkin,
Group Tax Director, BBC
Mariana Dias Ribeiro,
International Tax Adviser, Embraer
Brad del Matto,
Global Head of Tax, Nintex
Jay Das,
Principal, Deloitte

17.00 Close of day two

 

Speakers

Alan Krueger

Alan Krueger  

Bendheim Professor of Economics and Public Affairs
Princeton University

One of the nation’s most-respected economists, Alan Krueger served as chairman of President Obama’s Council of Economic Advisers (CEA) and a member of his Cabinet from 2011-2013, and he is among the 50 highest-ranked economists in the world according to Research Papers in Economics. He joined the administration amid the deepening recession and helped steer the country back toward growth. The former chief economist of both the Department of the Treasury and Department of Labor, he is not only one of the foremost experts on labor and unemployment, but he is also one of the people best poised to address our current economic environment. 



Edward Kleinbard

Edward Kleinbard  

Ivadelle and Theodore Johnson Professor of Law and Business
University of Southern California's Gould School of Law

Edward D. Kleinbard is The Ivadelle and Theodore Johnson Professor of Law and Business at the University of Southern California's Gould School of Law, and a Fellow at The Century Foundation. He is the author of a book, We Are Better Than This: How Government Should Spend Our Money, just published by Oxford U. Press. In reviewing the book, Pulitzer prize-winning journalist David Cay Johnston described it as "a masterpiece of tax, fiscal, and economic policy."

Professor Kleinbard joined USC Law in 2009. Before joining USC Law, Professor Kleinbard served as Chief of Staff of the U.S. Congress's Joint Committee on Taxation. The JCT Staff are the nonpartisan tax resource to Congress, helping legislators to formulate legislation, writing analyses of legislative proposals or tax issues of interest to the Congress, and estimating the revenue consequences of legislative proposals.

Professor Kleinbard's work focuses on the taxation of capital income, international tax issues, and the political economy of taxation. Professor Kleinbard's recent papers include Competitiveness Has Nothing to Do With It (Tax Notes), Stateless Income (Florida Tax Review), The Lessons of Stateless Income (Tax Law Review), Through a Latte Darkly: Starbucks's Stateless Income Planning (Tax Notes), The Better Base Case (Tax Notes), Herman Cain's 9-9-9 Plan (Tax Notes), and Tax Expenditure Framework Legislation (National Tax Journal). Professor Kleinbard has testified before the Congress on tax policy matters, and has written opinion pieces for the Wall Street Journal, New York Times, the Huffington Post, CNN.com, and other media outlets.

Prior to his appointment to the Staff of the Joint Committee on Taxation, Kleinbard was for over 20 years a partner in the New York office of Cleary Gottlieb Steen & Hamilton LLP. Professor Kleinbard received his J.D. from Yale Law School, and his M.A. in History and B.A. in Medieval and Renaissance Studies from Brown University.



Stephen Moore

Stephen Moore  

Distinguished Visiting Fellow, Project for Economic
Growth
The Heritage Foundation

Stephen Moore, who formerly wrote on the economy and public policy for The Wall Street Journal, is the Distinguished Visiting Fellow, Project for Economic Growth, at The Heritage Foundation.  Moore, who also was a member of The Journal’s editorial board, returned to Heritage in January 2014 -- about 25 years after his tenure as the leading conservative think tank’s Grover M. Hermann Fellow in Budgetary Affairs from 1984 to 1987.

As Distinguished Visiting Fellow at Heritage, Moore focuses on advancing public policies that increase the rate of economic growth to help the United States retain its position as the global economic superpower. He also works on budget, fiscal and monetary policy and showcases states that get fiscal houses in order.

Moore’s early career was shaped by three people who had a profound influence on him: Julian Simon, the late Cato Institute scholar; Edwin J. Feulner, a co-founder of Heritage; and Art Laffer, the economist best known for the Laffer curve.

Moore, who grew up in New Trier Township, Ill., received a bachelor of arts degree from University of Illinois at Urbana-Champaign. He holds a master’s of arts in economics from George Mason University.



John Hughes

John Hughes  

Acting Director, APMA Program
Internal Revenue Service 

John Hughes presently serves as Acting Director, APMA. Hughes joined the IRS in September 2011.

Prior to assuming his current assignment, Hughes was Senior International Advisor to the Director, Treaty and Transfer Pricing Operations. He has also been a Senior Manager in APMA.

Before joining the IRS, Hughes worked at the Washington offices of Mayer Brown. He received a JD and an MA (Applied Economics) from the University of Michigan in 1999.



William H. Morris

William Morris  

Director, Global Tax Policy
GE

Will Morris is currently Director, Global Tax Policy, in General Electric's corporate tax department.

At GE, Will works on a wide range of international tax matters relating to GE's foreign operations, with principal responsibility for coordinating GE's Global (non-US) tax policy program.

After private practice in London and Washington, DC, he joined the IRS in 1995, moving to the Office of Tax Policy at the US Treasury in January 1997 to work on international tax policy. Will was Associate International Tax Counsel until March 2000. At US Treasury his areas of responsibility included subpart F, foreign partnerships and other fiscally-transparent entities, and entity classification issues ("check-the-box").

Will was appointed Chair of the CBI Taxation Committee in London in May 2010, and is also Chair of the AmCham EU Tax Committee in Brussels. He was appointed Chair of the BIAC Tax Committee to the OECD in Paris in November 2012. He is also chair of the European Tax Policy Forum, a registered UK charity that since 2005 has commissioned 40 papers from leading academic economists into business tax issues.



António Calisto Pato

Antonio Calisto Pato  

Global Head of Tax
Chiquita Brands International

António is based in Chiquita's Regional office in Rolle, Switzerland. He has 13+ years of experience in managing international direct and indirect tax, transfer pricing, tax accounting, tax controversy & audit. He has previously worked as an international tax lawyer in different law firms, as a private equity consultant with PwC and as an EMEA Tax Manager for Cemex.

He has been with Chiquita Brands International since 2011 and he is responsible for taxes globally (North America - US, Canada and Mexico, - LATAM, EMEA and APAC). He has experience with Principal/Regional LRD model structures, IP structures, cash pooling and other financing structures, service centers and value chain structuring in general. He has specific experience with planning and compliance for CIT, VAT and Transfer Pricing and with US compliance and reporting. He has also experience in tax controversy having directly managed several audits and court cases from in Europe, US and Latin America.

António has been very much involved in supporting ERP implementation in different countries and in the drafting of an in-house VAT interface to automatise VAT in Chiquita's ERP. He has actively supported - both as advisor and within industry - mergers, acquisitions, spin-offs, take-overs and other type of restructuring.



Jonathan Silver

Jonathan Silver  

Managing Director, Head of Tax Counsel and Advisory
Jefferies

Jonathan Silver is a Managing Director and Head of Tax Counsel and Advisory at Jefferies.  In this capacity, Jonathan leads the Firm’s tax counsel (e.g., front office coverage), tax planning and international tax functions.  Jonathan was previously an Executive Director and tax counsel at Morgan Stanley, where he provided primary coverage for various business units including Commodities, Structured Credit, FX, Emerging Markets, OTC Derivatives Clearing and Structured Notes.  Prior to that, he was a tax associate at Fried Frank and Cadwalader.  In these roles, he focused on fund formation and M&A.  Jonathan is a graduate of Georgetown University Law Center, where he won the Prize for Best Paper in the John M. Olin Program in Law and Economics.  Jonathan regularly speaks on panels relating to financial products and international tax topics.



Mark Carrillo

Mark Carillo  

Director of Corporate Taxation
Ixia

Mark Carrillo is Director of Corporate Taxation at Ixia. He has extensive experience in accounting for income taxes (ASC 740) and the preparation and review of ASC 740 from start-up to Fortune 100 corporations. His industry experience includes: technology, bioscience, retail, banking, hospitality and regulated entities (public utilities).

Carrillo’s other experience includes accounting for uncertainty in income taxes (FIN 48), implementing and maintaining SOX controls for global corporations, corporate tax and flow through compliance for both multi-state and multinational entities. He has worked in international locations and led global teams in purchase price accounting / FAS 141R (business combinations), FAS 123R, research and development tax credit analysis.

Prior to his role at Ixia, Carrillo was a Senior Manager at both Moss Adams LLP and Deloitte. He started his career at PwC after graduating from the University of Southern California and California Polytechnic State University.



Carolina Graterol

 

Global Head of Tax and Transfer Pricing
Rosen Group

Maria Carolina Graterol is a lawyer, specialised in International taxation, with a Master in Business Administration MBA at HEC Paris (Ecole des Hautes Etudes Commerciales de Paris). She has more than 20 years of experience in the tax and transfer pricing area. 

Carolina has advised multinational companies in different industries, first in Latin America where she had her own law firm dedicated exclusively to tax practice specially, international tax litigations. In Europe, she has worked as in house tax and transfer price advisor for leading companies in the pharmaceutical, automobile, fast moving consumer good (FMCG) industry, and oil and mining sector.

She has led multiple business restructuring projects throughout her professional experience in Europe, including conversion of full-fledged distributors into commissionaires, conversion of full-fledged manufacturers into toll manufacturers, centralisation of procurements functions and supply chain reorganisations, and implementation of OECD/BEPS recommendations in multinational companies.



Mariana Dias Ribeiro

Mariana Dias Ribeiro  

International Tax Adviser
Embraer

Mariana is currently an International Tax Advisor at Embraer, one of the word’s main aircraft manufactures with operational units in various locations around the world. Being responsible for international tax planning strategies in Embraer, Mariana leads the Global Transfer Pricing policy of the Group aligning different tax regimes with the challenges of Brazilian tax rules.

Previously, Mariana have worked at PwC as an International Tax Manager for over 7 years, being part of the Brazilian desk in New York for over 2 years. Mariana has over 10 years of experience in assisting multinational companies in different industries with operations in Brazil, being involved  in numerous restructuring and tax planning projects.

Mariana holds a Bachelor’s degree in Law from Milton Campos University (Brazil), a L.L.M. degree in International Taxation from University of Leiden (The Netherlands) and an Executive Education in US Taxation at the University of South California (United States)



Erin Stuart-Cayot

Erin Stuart-Cayot  

Vice President, Global Tax
Fortinet

Erin Stuart-Cayot has extensive experience in leading the tax function, accounting for income tax, international tax structuring, planning, analysis, and tax compliance.

Stuart-Cayot has a valuable track record in achieving objectives and building relationships with outside service providers and taxing authorities in handling a number of accounting and tax related issues. She is also experienced with both manufacturing and software and in a vast amount of jurisdictions including all major countries in Asia and Europe as well as experienced in starting and re-organising tax departments in high technology company environments. As such, Stuart-Cayot has a comprehensive view of all tax issues facing high technology companies from developing strategic tax structures which impact the company's daily operations to managing all compliance and audits.



Shyamli Mohamed

Shyamli Mohamed   Director Tax, Global Transfer Pricing
Halliburton 

Shyamli Mohamed is currently Director Tax, Global Transfer Pricing at Halliburton Company, Houston.  Shyamli has over 15 years of International Oil & Gas industry experience and is also a Harvard Business School Alumni.

She has  lived and worked globally (in Asia, Africa, Europe, Middle East and North America) while serving  in various Senior Finance positions as, International Tax manager, Treasurer, Business Controller, Corporate reporting, Head of Finance Transformation management , Head of Business Analytics.



Keith Richey

Keith Richey  

International Tax Counsel
Xylem

Keith Richey is an international tax attorney with over 20 years of experience serving major U.S. 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 optimized 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.

Currently Keith is the International Tax Counsel for Xylem Inc., a leading global water technology provider that was recently spun-off from ITT Corporation.  Previously, Keith was International Tax Counsel for ITT Corporation, and before that Director International Taxes for Xerox Corporation, Senior International Tax Counsel for Citicorp (i.e., Citibank),  Tax Counsel for Mobil Oil, Senior Tax Attorney at Exxon, and summer clerk at Gibson, Dunn & Crutcher.

Keith 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 Treasuer; 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. Keith 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.



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).



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. 

Abhishek has been a member of various tax committees of leading business chambers like Confederation of Indian Industry (CII) etc. 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

 

 

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.

 



Ognian Stoichkov

Ognian Stoichkov  

Global Transfer Pricing Director
PepsiCo

Ognian Stoichkov currently serves as global transfer pricing director for PepsiCo, Inc. 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, Ognian spent 14 years with Big 4 transfer pricing practices in Detroit, Short Hills, NJ and New York.

He has a B.A. in Economics from Reed College, a M.A. in Economics and Ph.D. Candidacy in Economics from the University of Michigan, Ann Arbor.



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.



Todd Wolosoff

Todd Wolosoff   Global Transfer Pricing Leader
Deloitte

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 2011-2015.



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.



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, Rob has worked on contemporaneous documentation, planning, audit defense, and APAs.



Clive Tietjen

Clive Tietjen   Partner
Deloitte

Clive is a partner based in the Reading office in the firm's Global Transfer Pricing Group and leads the UK transfer pricing practice for the UK offices outside London.

Clive helps clients with all aspects of designing, implementing and operating transfer pricing policies and supporting those policies under audit. He leads the European and Global transfer pricing arrangements for a number of foreign owned and UK based multinational
groups. He has significant experience in helping businesses manage their transfer pricing risk through the structuring of arrangements which are practical and consistent with their business model, and addressing the transfer pricing and associated tax issues caused by
business change (including permanent establishment and exit considerations).

He also spends a lot of time partnering with clients to prepare robust bespoke documentation, helping them develop on-going compliance processes to monitor results and business changes as well as managing tax audits. In particular, more recently, he has been helping those clients adapt to the greater obligations being imposed by increasing local requirements, likely greater tax authority scrutiny and the proposals for more prescriptive central documentation contained in the OECD's Base Erosion and Profit Shifting Action 13. He is part of Deloitte's global group looking at developing processes and tools to help businesses manage these obligations.



Eva Parenti

Eva Parenti   Principal
Deloitte 

Eva Parenti is a principal in the Chicago office of Deloitte Tax LLP with 14 years of transfer pricing and valuation experience. Parenti has been serving for many years large domestic and foreign multinational companies, covering several industries, in the context of planning, documentation, and audit defense.

Parenti has extensive experience with global strategic tax reviews and business model optimisation strategies, including IP optimisation, supply chain restructuring, and procurement companies.

Parenti has assisted in the development of Deloitte's proprietary Digital Global Steps (DGS), an interactive software tool for ETR modeling and transfer pricing analytics and compliance. She is also part of the Deloitte Global Dox Platform for which she served as an important member of the global development team.



Keith Reams

Keith Reams   Principal
Deloitte

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 the US, Europe, UK. South America, and South East Asia. 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.



Ivan Mullinax

Ivan Mullinax   Managing Director
Deloitte 

Ivan Mullinax is a London-based director in the transfer pricing practice of Deloitte LLP. He has 18 years of experience in transfer pricing, the last 12 of which have been with Deloitte in London.

Ivan is a member of the UK Financial Services Transfer Pricing team and leads the private equity and insurance offerings. Ivan works with many of the world's leading private equity groups in developing and supporting their European pricing and also has supported audit defense work in Germany, India, Sweden, the UK and the US for private equity clients.

His practical and creative approach to transfer pricing has helped Ivan to develop solutions for challenging problems facing banking, funds and technology clients and helped Ivan when he led the team's support for M&A diligence into transfer pricing, where he helped identify and qualify potential transfer pricing exposures. He then worked with the acquiring group to structure transfer pricing aspects of the acquisition and integrate the arrangements.



Mark Nehoray

Mark Nehoray   Partner
Deloitte

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.

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; ecommerce; and non-profit). These projects have included both defensive work with respect to ongoing 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 programmes.



Philippe Penelle

Philippe Penelle   Principal
Deloitte

Philippe is a Principal with the Washington National Tax office of Deloitte Tax LLP, specializing in designing, valuing, and defending transactions that involve the transfer of intellectual property rights. Philippe 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 U.S. Code §704, contributions to corporations under 26 U.S. Code §367, and licensing arrangements involving specific allocations of fixed cost funding commitments.

In addition to his extensive client work in the Life Sciences, Technology, Video Game, Entertainment and Media, Fashion, and Retail industries, Philippe has published a number of articles developing valuation methodologies relevant to various intellectual property structures consistent with the OECD Transfer Pricing Guidelines, the Internal Revenue Code and the Treasury regulations promulgated thereunder. These articles have been published in Bloomberg BNA Transfer Pricing Report, International Tax Review, Global Tax Weekly, and Bloomberg BNA Tax Management Memorandum.

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 U.S. Treasury Department, and with the international business community. His involvement has included the drafting of comments submitted on behalf of Deloitte Tax LLP 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.



Paul Riley

Paul Riley   National Leader, Tax
Deloitte

Paul is a senior transfer pricing partner in the Deloitte Australia Tax & Legal practice. Prior to his appointment Paul was Deloitte’s Asia-Pacific transfer pricing leader for 3 years and leader of Victoria tax group for 1 year. Paul has over 30 years of experience, including ten years with the Australian Taxation Office and 20 years in public practice, with experience serving clients throughout Australia, Asia Pacific and the US. Paul has held many senior positions during his 17 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 currently is a member of Deloitte's Global Transfer Pricing Leadership Group and a member of Deloitte Global Tax & Legal BEPS Markets Steering Committee.



Boris Nemirov

Boris Nemirov   Partner
Deloitte

Boris Nemirov's experience includes over 15 years of transfer pricing economic consulting. 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 also actively participates in numerous national initiatives, including those aimed at Deloitte's response to BEPS and was nominated to appear in the 2013 Guide to the World's Leading Transfer Pricing Advisers, which was released in September 2014.



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 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.



Dave Varley

Dave Varley   Principal
Deloitte

Dave Varley is a Principal in Deloitte Tax LLP’s Washington National Tax Transfer Pricing practice.  Dave assists clients on a range of international tax subjects, focusing on transfer pricing risk management, Advance Pricing Agreements, Mutual Agreements, and related U.S. Competent Authority matters.  
 
Prior to joining Deloitte, Dave 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 U.S. treaty partners.  Through the field-based Transfer Pricing Practice, Dave 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. 
 
In over 14 years with the IRS, Dave has held a number of other important leadership roles.  He began his government career as a Team Leader for the Advance Pricing Agreement Program and then served as a Senior Counsel in Associate Chief Counsel International and as Special Assistant to the Deputy Commissioner, Services and Enforcement. Dave designed, built and led the new Treaty Assistance and Interpretation Team, the group within the U.S. Competent Authority Office dealing with all non-allocation and treaty interpretation issues, and also served as the acting Assistant Deputy Commissioner, International, where he was responsible for U.S. tax treaty administration functions including implementation of FATCA and the U.S. Competent Authority’s participation in the OECD and other international tax administration organisations. 



Kaoru Dahm

Kaoru Dahm   Principal
Deloitte

Kaoru K. Dahm is a principal in Deloitte Tax LLP’s Greater Washington office and specializes in transfer pricing. At Deloitte, Kaoru has assumed various leadership roles, including a Global Tax & Legal Manufacturing Industry Leader, a co-leader of U.S. Transfer Pricing Team Automotive Industry Group, and a U.S. leader of Deloitte Japanese Services Group Transfer Pricing Network. Kaoru has undertaken and supervised transfer pricing studies for advance pricing agreements (APAs), mutual agreement procedure (“MAP) cases, 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, including automobiles and automobile parts, consumer products, pharmaceuticals, chemical, biotech, e-commerce, medical equipment, computer software, industrial machinery, railcars, construction equipment, energy, and semiconductor sectors.  While at Caltech, Kaoru designed and written computer programs to simulate stochastic processes in financial studies and conducted numerous computerised experiments in the field of economics and finance.  Kaoru frequently meets with the U.S. tax authorities to negotiate various APA/MAP and audit defense cases, and presents solutions for analytically challenging issues. 

Kaoru has been recognized 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.”  Kaoru’s publications (with co-authors) 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 Analyzing 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); “Similarities and Differences in U.S. and Japanese Transfer Pricing Documentations” in Kokuzei Sokuho (June 10, 2011); and “Transfer Pricing in the Manufacturing Sector: Transformation and New Challenges” in International Tax Review (September 19, 2014).  Kaoru is a frequent speaker at business and professional conferences.



Bob Norton

Bob Norton   Principal
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.



Aydin Hayri

Aydin Hayri   Principal
Deloitte

Aydin Hayri serves as the life sciences industry leader for Deloitte's transfer pricing practice, and also manages Deloitte's Greater Washington and Philadelphia transfer pricing practice groups. He has been with Deloitte since 1998.

Hayri assists clients with transfer pricing planning involving intellectual property development, cost sharing, and licensing strategies; and planning and implementation of supply chain and business model restructurings. In addition to life sciences industry, his transfer pricing and tax planning experience covers defence/aerospace, and high-technology manufacturing, and software industries.



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 & Co Inc. 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.



Jivan Datta

Jivan Datta   Principal
Deloitte

Jivan B. Datta is a principal in Deloitte’s International Tax Global Services Group and focuses primarily on Business Model Optimisation (‘BMO’). Datta received a Bachelor of Arts degree from the University of Rochester, JD from American University’s Washington College of Law, and an LL.M. in taxation from the University of Miami.

Datta specialises in BMO planning with a focus on Consumer Products, Life Sciences as well as other industries. He has led multidisciplinary teams designing and implementing supply chains models in Asia, Europe and Latin America. Clients served include US and non-US based multinational companies.

Datta is a frequent speaker on supply chain planning including external seminars such as the National AICPA conference. He is a member of the Maryland Bar Association.



Rebel Curd

Rebel Curd   Vice President, Practice Leader of Transfer Pricing
Charles River Associates

Rebel Curd is a vice president in Charles River Associates’ Transfer Pricing Practice and leads the global practice. She is a former partner of The Ballentine Barbera Group, which was acquired by Charles River Associates in 2006. Curd has over two decades of experience in economic analysis and business valuations from a consulting and industry background.

Her areas of expertise within intercompany pricing include acquisition/integration planning, global compliance and planning, intellectual property valuation and migration, and controversy. She has participated in successful intercompany pricing audits involving negotiations with the Canadian, Danish, Finnish, French, German, Italian, Japanese, Swiss, UK, and US taxing authorities. In addition to intercompany pricing analyses, Curd has experience in business valuations, economic value management, economic impact analyses, activity based costing, and econometric modelling.

Curd was selected as “Best of the Best, United States” for Transfer Pricing in Expert Guides in 2013, 2014, and 2015. CRA was named “Transfer Pricing Firm of the Year – USA” for 2015 by Finance Monthly Tax Awards. Additionally, Curd’s office was awarded the “San Francisco Area Transfer Pricing Firm of the Year” in 2011 by International Tax Review.

Prior to joining The Ballentine Barbera Group and Charles River Associates, Curd worked at Bio-Rad Laboratories, Inc. and KPMG’s Economic Consulting Services.



David Forst

David Forst   Partner, Practice Group Leader - Tax
Fenwick & West

David L. Forst is the Practice Group Leader of the Tax Group of Fenwick & West where he focuses on international corporate taxation. David is included in 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). David 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.

David 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. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.



Sam Cicogna

Sam Cicogna   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, Sam 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 Sam to directly understand market needs and the challenges of end users interacting with our software and services on a daily basis. 

Sam 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.
 
Sam 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 & the Association for Computers & Taxation, and is currently based in Atlanta, GA. 



James Wiley

James Wiley   Director, Transfer Pricing
Thomson Reuters

James leads the Professional Services Transfer Pricing team at Thomson Reuters that provides complimentary support to the ONESOURCE Transfer Pricing technology solution.  In this role, James and his global team work with a wide range of clients across multiple industries and assist with benchmarking, documentation and other transfer pricing related work.

Prior to joining Thomson Reuters, James spent eight years with PwC in London, Tokyo and New York and, most recently, two years with JPMorgan as part of the tax planning group with responsibility for global transfer pricing.

 

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