Declining revenues. Unilateral actions by local tax authorities. Uncertainties created by outside financial auditors in reaction to PCAOB actions. Energy companies must face these challenges and more during this time of dramatic change in the industry. Throughout all of this, CFOs and Tax VPs must remain vigilant and informed on ways to maximize value. In response, Bloomberg BNA, in partnership with Mayer Brown, is hosting the 3rd Annual Energy Tax Conference: Maximizing Value to help energy company finance and tax executives deal with the constant pressure to add incremental value to their organizations’ bottom line.
This must-attend event will feature government officials, policy makers, industry leaders and advisors who will confer on the most critical topics impacting energy tax companies at the international, federal and state levels. Sessions will cover capital restructuring, the implementation of the BEPS action plan, a workshop on drafting intercompany agreements, a Latin America update, the best practices for driving legislative and regulatory changes, and more.
The conference will also feature, in partnership with the Houston TEI Chapter, a special CFO and VP Tax Roundtable session, where panelists will discuss managing risk, working with other parts of their organizations, and how tax can support the company in maximizing value.
8:00 am - 8:30 am Breakfast and Registration
8:30 am - 8:50 am State of the Energy Industry
David Stover, CEO, Noble Energy, Inc., Houston
8:50 am – 9:40 am Important Tax Considerations When Reacting to the Down Market
Energy companies have reacted to the
down market in various ways, including restructuring debt, issuing new equity,
swapping debt for equity, strategic consolidation, asset sales, loss
carrybacks, and bankruptcy. This session
will discuss the tax consequences and important tax considerations of these
various reactions to the down market.
Moderator: Jason S. Bazar, Partner, Mayer Brown, New York
Panelists: Jonathan Forrest,Principal, Deloitte, Washington, DC; William “Lynn” Loden, Managing Director, Transaction Support and Taxation, Opportune, LLP, Houston; Yinka Kukoyi, Partner – Mergers & Acquisitions Tax, KPMG, Houston
9:40 am - 10:30 am Tax Policy Workshop: Best Practices for Effecting Legislative and Regulatory Change
Significant changes to the Internal Revenue Code and Treasury regulations recently will shape how energy companies will do business in the future. This session will discuss how tax executives of energy companies can participate in the legislative and regulatory rule-making process. Many times there are opportunities to comment on proposed regulations or to meet with the staff of the Congressional committees to provide drafting ideas for legislative amendments. This participation in the process is welcome and necessary for prudent changes. This session will discuss some ways for tax departments to become more involved in the legislative and regulatory process.
Moderator: Warren Payne, Senior Tax and Trade Policy Advisor, Mayer Brown, Washington, DC
Panelists: Thomas Kittle-Kamp, Partner, Mayer Brown, Chicago; Aaron Lorenzo, Senior Congressional Reporter, Bloomberg BNA; Emily Whittenburg, Senior Tax Advisor, Tax Policy & Government Relations, Shell Oil Company, Houston
10:30 am - 10:45 am Break for Refreshments
10:45 am - 11:15 am Opening Keynote Address
U.S. Congressman Kevin Brady, Chairman, House Ways & Means Committee, Washington, DC
11:15 am - 12:15 pm Implementation of BEPS
Energy companies are faced with the
decision on how to implement the OECD BEPS project action plans, including
country-by-country reporting during the “gap” year, hybrid entities given the
proposed U.S. section 385 regulations, the recently published profit-split
report and changing views on permanent establishments. This panel will discuss the impact of the
BEPS project on businesses as they face changing U.S., European, and foreign
tax environments. The audience will hear
from U.S. Government representatives, industry, and advisory firms on how to
adapt to the changing environment.
Moderator: Clifford Mangano, Director of Global Transfer Pricing, Diamond Offshore Drilling, Houston
Panelists: James Hill, Partner, Mayer Brown, London; John C. Hughes, Director (Acting), Advance Pricing and Mutual Agreement Program, Internal Revenue Service, Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, U.S. Department the Treasury, Washington, DC; Ingo Kleutgens, Partner, Mayer Brown, Frankfurt; Kathryn O’Brien, Principal, Transfer Pricing, PwC, Washington, DC
12:15 pm - 1:45 pm Luncheon Session with Keynote Address
Tina Meaux, Director of the Central Compliance Area, Large Business and International Division, Internal Revenue Service, Houston
1:45 pm - 2:45 pm The Importance of Well Drafted Intercompany Agreements in Tax Planning
Intercompany agreements generally form the basis of a
company’s economic, functional, legal, and tax positions. The IRS and worldwide
tax authorities routinely request copies of intercompany agreements during
examinations of energy companies. A poorly-drafted intercompany agreement may
deprive a taxpayer of the benefits of good tax planning and generate
unnecessary tax controversies. This session will present the best practices in preparing
intercompany agreements using real examples of energy company agreements to
demonstrate how to bolster a taxpayer’s tax positions. The audience will gain
practical on how to formulate intercompany agreements that will be beneficial,
defensible, and sufficiently flexible for the company and will acquire expert
insights on the steps to ensure that key items are taken into account –
such as BEPS developments, the invalidation of regulatory requirements,
and other important changes, like proposed regulations such as those
promulgated under section 385.
Moderator: Scott M. Stewart, Tax Controversy Partner, Mayer Brown, Chicago
Panelists: LaWonda Love, Director, Research & Planning - Tax Department, Spectra Energy Corp, Houston; Victor Nieto, Senior Director, Tax Special Projects, Weatherford International, Ltd, Houston; Joseph Tobin, Senior Manager, Global Transfer Pricing, Deloitte, Dallas
2:45 pm – 3:00 pm Break for Refreshment
3:00 pm - 4:00 pm Meeting US and Global Transfer Pricing Requirement
The country-by-country reporting (CbCR) requirements, proposed U.S. section 1.482-1T transfer pricing regulations, and various court cases have created new challenges for global energy companies as they meet their global transfer pricing requirements. Well defined transfer pricing policies and strongly developed local, master and CbCR documentation will assist the company in navigating the uncertainties created by the BEPS action plans and U.S. Treasury’s proposed regulations. The audience will learn the latest developments affecting U.S. taxpayers and practical tips on how to address their company’s changing transfer pricing needs.
Moderator: Clifford Mangano, Director of Global Transfer Pricing, Diamond Offshore Drilling, Houston
Panelists: David Canale, Principal, Transfer Pricing Controversy, EY, Washington, DC; John C. Hughes, Director (Acting), Advance Pricing and Mutual Agreement Program, Internal Revenue Service,Washington, DC; Hamish McElwee, Transfer Pricing Partner, PwC, Perth Western Australia; Jason Osborn, Partner, Mayer Brown, Washington, DC; Kathrin Zoeller, Senior Director Transfer Pricing, Weatherford International Ltd., Houston
4:00 pm - 5:30 pm CFO & VP Tax Round Table
Market volatility and uncertainty has been a great stress on the energy industry over the past couple of years. Tax plays a greater role in all segments of the energy sector than ever before. From positively impacting major business decisions and working more closely and effectively with their CFO counterparts, the tax department contributes to the success of the overall business. This moderated roundtable will provide an open dialogue for our CFO and VP Tax panelists to provide their thoughts and experiences in managing risk, working together with other parts of the organization, and how tax should support the company in maximizing value. The panelists will provide a candid view on the role of the tax department in dealing with the major issues we are discussing at the Conference.
Moderator: Emily Whittenburg, Senior Tax Advisor, Tax Policy & Government Relations, Shell Oil Company, Houston
Panelists: Shaun Ahn, Head of Tax, Westlake Chemical, Houston; Jonathan Batarseh, Vice President – Tax, KBR, Inc., Houston; Steve Bender, SVP, Chief Financial Officer, Westlake Chemical, Houston; Kenneth M. Fisher, Executive Vice President & Chief Financial Officer, Noble Energy, Inc., Houston; Amy Jolley, Vice President of Tax, Noble Energy, Inc., Houston; Louis Teuscher, Director Tax Affairs North America, Repsol USA Holdings, Inc., The Woodlands,TX
5:30 pm Cocktail Reception at Hyatt Regency
8:30 am - 9:00 am Breakfast
9:00 am - 9:30 am Keynote Address
Bruce Culpepper, President, Shell Oil Company, Houston
9:30 am - 10:30 am What’s New in the MLP Space?
Master limited partnerships have been around for more than 30 years, but do they continue to be as popular as ever? This panel will consider the recent consolidation in the area, the conversion of several MLPs to regular corporation status, alternative structures such as the Yieldco, and MLP structures for offshore operations. Special focus will be on the effect of the current state of the energy industry on MLPs and their unitholders, including the possibility of cancellation of debt income, initial public offerings, and other concerns. The latest developments with respect to qualifying income eligible for the natural resources exception will also be addressed. The panelists will offer their views from the standpoints of the VP-Tax and legal, accounting and banking advisors.
Moderator: Ed Osterberg, Partner, Mayer Brown, Houston
Panelists: Cheryl Claybough, Director, Pass Through Entities, LB&I, Internal Revenue Service, Washington, DC; Kasey Dunn, Tax Partner, PwC, Houston; Penny Houy, VP - Tax, Enterprise Products, Houston; Timothy Fenn, Partner, Latham & Watkins, Houston; Greg Matlock, Partner & US MLP Leader, EY, Houston
10:30 am - 10:45 am Break for Refreshments
10:45 am - 11:45 am Trending IRS Tax Controversy Issues Facing the Energy Industry
IRS enforcement of specific issues facing the energy
industry has allowed tax departments and tax advisors to spot trends of tax
enforcement. Many of the issues that IRS is focused on relate to the tax
aspects of the global structure of energy companies. This session will
discuss tax controversy issues that are trending for energy companies and the
best practices to prepare a defense.
Moderator: Brian Kittle, Partner, Mayer Brown, New York
Panelists: Mickey Culpepper, Director of Tax US & Non-US Audit Resolution, Baker Hughes, Houston; John Hurley, Tax Counsel, Halliburton, Houston; Keith Jones, International Tax Accountant, PwC, Washington, DC
11:45 am - 12:45 pm Managing a Tax Department under the Current Financial Audits and PCAOB Environment
Tax departments are routinely required to interact with the financial auditors. who are scrutinizing companies’ tax positions. The PCAOB’s increased focus on tax has caused financial auditors to closely examine a company’s analysis supporting its tax positions. This session will assist tax executives with understanding the standards promulgated by PCAOB and the methods used by a company’s financial auditors so tax executives can better manage the tax aspects of a financial audit.
Moderator: Shawn O’Brien, Partner, Mayer Brown, Houston
Panelists: Myrtle Jones, Senior Vice President, Tax, Halliburton, Houston; Paul Mundwiller, Partner, Tax, KPMG, Houston; Robert Tockman, Partner, Audit, KPMG, Houston
12:45 pm - 2:00 pm Keynote Luncheon: Presidential Politics and the Prospects for Tax Reform in 2017
Stephen J. Entin, Senior Fellow, Tax Foundation, Washington, DC
*** From 2:00 pm until 4:00 pm, attendees will have the option to attend one of two breakout tracks, which will focus on international tax issues and state tax issues. ***
2:00 pm - 3:00 pm International Market Developments
Over the last few years the need for tax revenues has forced countries to identify alternative ways a tax authority can collect revenue from multinational companies. Countries are re-characterizing business profits through diverted profit tax regimes, using domestic law to increase the number of denied deductions, and readdressing the concept of permanent establishment. In many cases, these actions are being done under the auspices of the OECD BEPS project and in other cases, they are unilateral actions going beyond BEPS. Compounding the situation is the use by the EU commission of state aid legislation to question the legitimacy of local country rulings. In reaction, companies must change their approach to international tax planning. This session will provide insight into recent developments in the area and how companies are approaching these developments.
Moderator: James Hill, Partner, Mayer Brown, London
Panelists: Ingo Kleutgens, Partner, Mayer Brown, Frankfurt; Hamish McElwee, Transfer Pricing Partner, PwC, Perth Western Australia; Nico Tran, Senior Tax Counsel, ConocoPhillips, Houston
2:00 pm - 3:00 pm A Review of State Oil and Gas Tax Cases
This panel will review recent state tax cases affecting the oil and gas industry. Topics covered will include litigation about sales and use taxes, credits and exemptions, and property tax issues, among others.
Moderator: Christine Cagnina, Attorney, Mayer Brown, Charlotte
Panelists: Jesse R. Adams III, Partner, Jones Walker, LLP, New Orleans; Paul DiSangro, Partner, Mayer Brown, Palo Alto; Annabelle Gibson, Managing Editor - State Excise Taxes and Industries, Bloomberg BNA, Arlington
3:00 pm - 4:00 pm International – Latin American Market Update
Latin American countries have complex, multi-level tax systems which are challenging to even the most sophisticated energy company tax departments. Especially challenging are the multitude of tax compliance rules and the persistent attack on the oil and gas industry through audit adjustments and the court system. This session will provide an update of the latest court decisions and best tax practices relied on by oil and gas companies as they navigate Latin America’s complex tax regimes.
Moderator: Ivan Tauil, Partner, Mayer Brown, Rio de Janeiro
Panelists: Bernardo Ramirez, Partner, Chevez Ruiz Zamarripa, Mexico DF; Eduardo Telles, Partner, Mayer Brown, Rio de Janeiro
3:00 pm – 4:00 pm States’ Reactions to Decreasing Oil Prices
State tax revenues dependent on oil have plummeted in recent months, corresponding with the fall in prices. States now are tasked with determining how to make up budget shortfalls in the down market. Proposals for changing industry credits and exemptions or imposing higher severance taxes are just a few ideas that legislatures have considered as methods of generating additional revenue. This panel will discuss how states are coping with lower oil prices and will review changes to tax regimes that affect the oil and gas industry at the state level.
Moderator: Paul Broman, Senior Managing Tax Counsel, BP, Houston
Panelists: Dale Craymer, President, Texas Taxpayers and Research Association, Austin; Paul DiSangro, Partner, Mayer Brown, Palo Alto; Kara Moriarty, President & CEO, Alaska Oil and Gas Association, Anchorage
4:00 pm - 4:15 pm Closing Remarks in Break Out Sessions
Congressman Brady is Deputy Whip and Vice Chairman of the Joint Economic Committee. He is a senior member on the House Ways and Means Committee where he is the chairman of the Health Subcommittee as well as a member of the Trade and the Social Security Subcommittees.
Christine Cagnina practices in Mayer Brown's Tax Transactions Group as Counsel in the Charlotte office. She focuses her practice on multi-state tax transactions and planning, including advising clients on the state tax aspects of mergers, acquisitions, reorganizations, the restructure of debt and private equity transactions as well as general corporate tax matters. Christine has substantial experience in multiple areas of state and local taxation, including income, franchise, sales/use and real estate transfer tax research, planning and analysis for tax minimization strategies, including structuring and tax planning for REITs, partnerships and limited liability companies investing in real estate and real estate-related assets. She has extensive experience working with various types of business entities, including corporate, partnership, and trust entities, engaged in real estate investments, finance and banking, electronic commerce, manufacturing, insurance, leasing, retailing, telecommunications and the oil and gas industry.
Paul DiSangro focuses his practice on resolving tax disputes with the IRS and state agencies. Paul obtains favorable results in an efficient time frame by collaborating with clients to develop a clear strategy for navigating the thorny issues that arise in complex tax cases. He has more than 20 years’ experience, representing clients in all facets of tax controversy, including audits and administrative appeals, alternative dispute resolution, and litigation. Paul is recognized as a leading tax controversy adviser in the Tax Controversy Leaders Guide2016. Paul has written several important works on US and international tax issues, and speaks and presents at professional tax seminars and symposia. He is the organiser of the annual Tax Controversy Seminar in Silicon Valley with the Tax Executives Institute. In addition, he has taught international tax classes as an adjunct professor at the LLM level. Prior to joining Mayer Brown in 2003, Paul practiced in Washington DC and San Francisco with two other prominent international law firms.
James Hill is a Partner in the London office of Mayer Brown's Tax and Employment & Benefits practices. He focuses on the corporate taxation aspects of mergers and acquisitions, group reorganizations, and corporate finance. He advises clients on a wide range of tax issues including the tax consequences of selling businesses, structures for business acquisitions, intra-group transfers of businesses, international structures and treaty claims, solvent and insolvent reconstructions, tax issues arising on the exploitation of IP, partnership structures, the taxation of debt and venture capital investments. James also focuses on the employment tax consequences of share incentives, carried interest arrangements, bonus plans, and other benefits. He advises clients on various employment related tax matters including share options, long term incentive plans, flowering shares, employee benefit trusts, the taxation of termination payments, internationally mobile employees, disguised remuneration and the bank payroll tax.
Myrtle L. Jones is Halliburton’s Senior Vice President of Tax. Based in Houston, Texas, she has more than 30 years of experience in international and domestic tax compliance and strategic tax planning. Before joining Halliburton in this role in 2013, Ms. Jones served as Senior Managing Director of Tax and Internal Audit for Service Corporation International (SCI) in Houston. In her role as tthe Chief Tax Officer for SCI, she managed all aspects of federal, foreign and state income taxes, sales and use taxes, property taxes, accounting for income tax, tax audits and tax planning. For the last two years, she also provided oversight to SCI’s Internal Audit function and led that team through a major transformational improvement process. Prior to joining SCI in 2008, Ms. Jones was Vice President of Tax for GlobalSantaFe Corporation, where she was responsible for developing and implementing worldwide tax planning strategies, tax risk management, and income tax reporting. She is a member of Tax Executives Institute and The International Tax Forum of Houston.
Tom Kittle-Kamp is co-leader of Mayer Brown’s Tax Controversy and Transfer Pricing practice. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterization, valuation disputes, capitalization questions, Subpart F and other international tax issues, Subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS Appeals (including Fast Track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes. Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licenses, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter.
Yinka Kukoyi has over 16 years of experience in tax planning and is a Partner in the KPMG M&A Tax practice specializing in mergers, acquisitions and divestiture planning. Mr. Kukoyi has extensive experience providing tax consulting services to companies in connection with corporate bankruptcies, debt workouts, ownership changes, reorganizations, legal entity rationalization, and divestitures, with a keen eye toward preserving and maximizing valuable tax attributes. In addition, Mr. Kukoyi has spent a significant amount of his career assisting private equity and strategic clients with due diligence and tax structuring services in connection with acquisitions and divestitures. He serves clients in the manufacturing, healthcare, oil & gas, power & utility, mining, and consumer products industries.
Greg Matlock is a Partner in Ernst & Young’s National Tax Department – Energy (House based). Prior to joining EY, Greg was a tax lawyer at Norton Rose Fulbright. Greg serves as EY’s US Master Limited Partnership (MLP) Leader and also serves as EY’s Energy Fund Oil and Gas Center of Excellence (COE) Markets Leader. Greg has lead numerous, significant MLP and public monetization feasibility projects and analysis (including MLP IPO structure analysis, qualifying income analysis, as well as other tax and economic planning matters), and has worked on MLPs and public transactions both as a lawyer and in his current role at EY. Similarly, Greg has assisted companies in evaluating various public monetization structures, including MLPs, Up-C transactions, C Corporation IPOs, YieldCos, and REITs. Greg is a frequent speaker (and writer) on MLP issues, as well as on energy tax and transaction matters. Greg has represented investors and companies in various types of inbound and domestic oil and gas investments and transactions, including tax partnerships, limited partnerships, and other joint venture structures, including tax issues related to such structures.
Shawn O’Brien is a tax controversy partner in Mayer Brown’s Houston office. Shawn represents clients in all types of tax disputes with taxing authorities on international, federal and state levels. He routinely advises clients on various tax issues during tax examinations, in administrative appeals and as an advocate in trial and appellate litigation before the US Tax Court, US District Courts and US Court of Federal Claims. Shawn’s tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, debt versus equity issues, international withholdings, advance pricing agreements, tax shelter disallowances, estate and gift tax valuations, research and development tax credits, excise taxes, and changes in accounting methods. Shawn advises foreign and domestic corporations, partnerships, MLPs, and LLCs seeking corporate and tax advice in connection with various types of foreign and domestic transactions, including mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings, and oil and gas transactions. Shawn is particularly focused on a variety of tax issues facing the energy industry including tax controversy, restructuring, acquisition and disposition of energy assets. Shawn served as chairman of the committee for energy and natural resources of the State Bar of Texas Tax Section from 2011 to 2013.
Ed Osterberg is a Tax Transactions & Consulting partner in Mayer Brown’s Houston office. His extensive experience includes all areas of business income taxation, with emphasis on corporate and partnership taxation and international transactions. Ed has advised corporate and individual clients on the federal tax consequences of various transactions, including 1031 exchanges, mergers and acquisitions; tax-free reorganizations; corporate spin-offs and other divestitures; partnerships; foreign operations, including cross-border joint ventures with non-US partners; and inbound investment into the United States by non-US investors. Ed is President of the International Fiscal Association USA Branch. Chambers USA 2015 refers to Ed as “tremendous” and he is held in high regard for his expertise in international tax transactions.
Bernardo Ramirez is a partner at Chevez Ruiz Zamarripa in Mexico City, Mexico. He joined Chevez Ruiz in 1993 and has been a partner since 2004. He has extensive experience on infrastructure development projects, mergers and acquisitions and inbound investments. He has taught tax-related subjects in different universities in Mexico for over 10 years. He has been a speaker in numerous tax seminars in Mexico and abroad.
Ivan Tauil is the founding partner and Head of the tax law practice of Tauil & Chequer Advogados in association with Mayer Brown and serves on Mayer Brown’s Partnership Board. He has extensive experience in local and international taxation. He is also the author of several articles and is often a lecturer at a number of legal and corporate events in Brazil and abroad. Ivan holds an LLM in constitutional law and theory of the state from PUC-RJ. He is the Chairman of the Oil & Gas Committee of the Brazilian Bar Association, Rio de Janeiro Chapter, Director of the Brazilian Tax Law Academy, and a member of the Brazilian Finance Law Association, the International Fiscal Association and the International Bar Association. In addition, Ivan is also a member of the Editorial Board of Revista Tributária e de Finanças Públicas - Ed. Revista dos Tribunais. In 2014, both Chambers Global and Chambers Latin America recognized him as one of the “Leaders in their Field” for his legal work in the tax sector.
Louis Teuscher joined Repsol, then Talisman Energy, in 2009. From 2006 to 2009, Louis worke with Kraton Polymer Holding (Houston), as Global Tax Director, and held several senior tax positions with Schlumberger in the US, Europe, and Asia. A CTA (Certified Tax Accountant), Louis holds a US Masters in Taxation from the University of Tulsa, as well as a European Masters in Taxation and BBA. Mr. Teuscher is a graduate of the Advance Management Program at Harvard Business School. He was chairman of the E-business Committee for the Tax Executive Institute (2001 – 2003). He is also a member of Financial Executives International (FEI) and the Harvard Alumni Association.
Kathrin Zoeller is a Senior Director of Transfer Pricing at Weatherford International’s Houston office. She joined Weatherford in 2012 to establish a team of economists responsible for transfer pricing as part of an overhaul of the tax department. Prior to joining Weatherford, she started in-house transfer pricing functions for News Corporation, Diageo North America, and Siemens North America. Her work has spanned several industries that have been characterized by IP intangibles and marketing intangibles. Kathrin also worked at Arthur Andersen as a member of the New York transfer pricing group until 2002. Her other work experience includes value chain analysis and corporate strategy work for corporate Strategic Planning at Siemens US and management consulting at the Munich Reinsurance group. Kathrin came to the US as an exchange student and stayed to graduate with a PhD in economics from the University of Georgia. Her research interests include industrial organization and monetary economics.
Jason Bazar is Co-Chair of Mayer Brown’s firm-wide Tax Transactions & Consulting practice. He advises corporate, banking and investment fund clients on the tax aspects of financing and business combination transactions. His guidance to domestic and foreign clients includes planning the tax aspects of taxable and tax-free mergers, acquisitions, divestitures, spin-offs and restructurings. Jason also counsels clients on the capitalization and structuring of inbound and outbound operations, including branches and subsidiaries, and general corporate and international tax planning matters. Jason regularly advises clients on the tax aspects of cross-border and domestic financing transactions, including leveraged financings, asset-based loans, securitizations and other structured financings, as well as lease transactions. In the capital markets area, he counsels clients on the tax aspects of debt, equity and hybrid securities offerings, US and non-US financial instruments and other capital markets transactions. Jason is Chair-Elect of the ABA Tax Section’s Committee on US Activities of Foreigners and Tax Treaties and Chambers USA recently recognized Jason as “Up and Coming” within the New York Tax arena, stating, “he has forged a reputation for being ‘very good at complicated transactions, very good at navigating them, and able to keep a relationship on good and friendly terms.’”
Dave Canale is the Principal of Transfer Pricing Controversy at EY in Washington, DC. He has over 20 years of experience in transfer pricing and advises both US and foreign-based multinational companies on transfer pricing controversy and risk management, planning and structuring. Dave works with companies in a variety of industry sectors, including pharmaceutical, medical device, electronics, computer, telecommunications, energy, entertainment, automotive, heavy manufacturing, food and beverage, including alcoholic beverages, consumer goods, apparel, publishing and information services, retail and chemical. Prior to joining EY, Dave served with the Internal Revenue Service’s APA Program in the Office of Associate Chief Counsel (International). He was acting branch chief for the program and served as program coordinator for all bilateral APAs with Canada. He also developed strategies and coordinated with the US competent authority regarding negotiations with various treaty partners. Dave’s combined IRS and private practice APA and MAP experience includes well over 200 cases, comprising files with Japan, Canada, Mexico, UK, Germany, France, The Netherlands, Switzerland, Belgium, Australia, China, India, Korea and Indonesia.
Charles Timothy (“Tim”) Fenn is a partner in the Houston office of Latham & Watkins with a particular focus on business taxation as it applies to partnerships. He represents publicly traded partnerships, master limited partnerships (MLPs) and other clients in the energy sector, as well as corporations, private equity firms, investment banks, partnerships and individuals on tax-related issues involving mergers, acquisitions, restructurings and capital market transactions. Mr. Fenn has served as tax counsel to over 75 issuers and underwriters in initial public offerings of equity securities of MLPs. He serves on the advisory board for the Alerian MLP index.
Keith is currently a Managing Director in PwC's Tax Controversy and Regulatory Services practice in Washington, DC. Prior to joining PwC in 2012, Keith worked at the Internal Revenue Service for over 30 years, where he held several executive level positions. His last assignment was as Industry Director, Natural Resources and Construction in Houston, a position he held for 7 years. His responsibilities included energy tax issues, both technical guidance and compliance responsibilities.
Brian Kittle is co-leader of Mayer Brown’s tax controversy & transfer pricing practice. Since joining the firm in 2006, Brian has represented clients in every facet of tax controversy and litigation. This includes IRS examinations and administrative appeals, through the litigation, including having a lead role in the recent Eaton transfer pricing US Tax Court litigation, of highly complex tax controversies involving a broad range of international and domestic tax issues. His controversy experience also includes frequent use of IRS alternative dispute resolution tools, including pre-filing and advance pricing agreements, and defending taxpayers in summons enforcement proceedings. In addition to his controversy practice, Brian tax advice on related party and highly-sophisticated transactions involving acquisitions and integrations. He also frequently speaks and writes articles about substantive and procedural tax issues. Brian has been repeatedly recognized as a rising star by International Tax Review’s Tax Controversy Leaders guide and Super Lawyers. He was also recently recognized by Chambers USA as a noted practitioner for tax in New York.
Dr. Ingo Kleutgens is a partner in the Frankfurt office of Mayer Brown's Tax practice. He advises on all tax issues related to corporate and finance transactions. He is dual qualified, as lawyer and tax consultant (Steuerberater), and is a certified advisor for international tax law (Fachberater Internationales Steuerrecht). Ingo is vice president of the Hessian Chamber of Tax Consultants and a member of the committee on International Tax Law at the Federal Chamber of Tax Consultants. He is author of various treatises and articles related to tax law and a regular speaker at conferences.
Cliff Mangano is currently the Director of Global Transfer Pricing at Diamond Offshore Drilling, Inc., where he is responsible for developing and managing Diamond’s transfer pricing policies and procedures. Cliff is also an Adjust Professor at the University of Houston’s Bauer School of Business where he teaches a graduate-level transfer pricing course for the Department of Accounting and Taxation. Prior to rejoining industry, Cliff was a US Subject Matter Expert for oil and gas, oilfield service companies, energy and mineral transfer pricing issues at PwC. His experiences at two Big 4 accounting firms includes transfer pricing and tax planning and compliance, and economic analysis with special emphasis in the oil and gas and minerals industries, oil field services, and drilling industry. He has also worked at the IRS as a senior economist for the Petroleum Industry Program where he was involved in various aspects of internal taxation, including economic support for issues concerning transfer pricing, litigation support, competent authority negotiations, and APAs. Cliff is a member of the Tax Executive Institute an the International Association of Drilling Contractors. He has a PhD in Mineral Economics from the University of Arizona.
Kara came to Alaska from her home state of South Dakota to teach elementary school in Atqasuk, an Inupiaq village in the North Slope Borough. After working in Washington, DC for, then South Dakota Congressman, now US Senator John Thune, she moved back to Alaska and lived in Fairbanks for seven years. She has served as legislative staff in Juneau to Senator Gary Wilken and was the President/CEO of the Fairbanks Chamber for four years. She joined the AOGA staff in April 2005. She became the fifth Executive Director of AOGA on January 1, 2012. She became President/CEO December of 2013. She is a 2003 recipient of Alaska's Top 40 Under 40 Award and was the Honorary Iceman at Eielson Air Force Base. She is a member of the Downtown Rotary Club of Anchorage and serves on the Executive Committee of the Resource Development Council. In her spare time, she can be found volunteering in full Jaguars gear on any given day as her children's "football mom." Her husband, Gerry, is an Alaska Airlines pilot and they enjoy their three young children, Joseph, Margaret and Garrett.
Jason Osborn is a tax partner in the firm’s Washington, DC, office focusing primarily on transfer pricing and other international tax issues. He represents multinational clients in a wide range of industries in negotiations for bilateral advance pricing agreements (APAs) and in competent authority matters and transfer pricing controversies. He also provides multinational clients with sophisticated international tax planning services. His transfer pricing experience and insight is extensive and varied, and includes cost sharing arrangements, transfers of tangible and intangible property, intercompany services, intercompany loans and guarantees, global dealing and cross-border restructurings. His industry experience includes pharmaceuticals, software, electronics, financial institutions, insurance, automotive, consumer products, energy and transportation, among other industries. Jason served from 2008 through 2012 in the IRS Office of Associate Chief Counsel (International), most recently as senior technical reviewer in the transfer pricing branch, and before that, as a team leader in the APA Program. In this connection, he provided technical and strategic guidance and advice to the IRS in matters related to transfer pricing, negotiated a significant number of complex APAs, and served as a member of the APA Program’s coordination group for financial institutions. Leveraging his recent government experience, Jason brings to the table a unique and current perspective in advising clients and negotiating APAs and resolutions of transfer pricing controversies. Prior to joining the IRS, Jason was a Tax Associate at Mayer Brown from 2003 to 2008. He began his legal career in 2001 as a tax associate in the New York office of another multinational law firm. Jason is a frequent speaker and author on topics related to transfer pricing, APAs, competent authority and the OECD.
Warren S. Payne is a senior advisor in Mayer Brown's Washington DC office and a member of the Tax, Government Relations, and International Trade practices. He joined Mayer Brown from the US House of Representatives Committee on Ways and Means, where he held a number of staff leadership roles over the past eight years, including his most recent position as policy director. As the Committee's policy director Warren was responsible for developing policy in all areas within the Committee's jurisdiction. Major legislation that Warren worked to enact into law includes the Tax Increase Prevention Act, the ABLE Act, the Middle Class Tax Relief and Job Creation Act, two highway and infrastructure funding bills in 2012 and 2014, and free trade agreements with Colombia, Peru, Panama and South Korea. In addition, Warren was responsible for the development and introduction of the first detailed legislation since 1986 to comprehensively reform the US Tax Code with the introduction of the Tax Reform Act of 2014. Other major pieces of legislation developed by the Committee during Warren's tenure as policy director include the Bipartisan Congressional Trade Priorities Act of 2014 and the SGR Repeal and Provider Payment Modernization Act. Before joining the Ways and Means Committee, Warren served as an economic advisor and international trade analyst at the US International Trade Commission. He also consulted on international trade and tax issues at Economic Consulting Services.
Since joining Mayer Brown in 1989, Scott Stewart’s practice has focused exclusively on tax disputes, including transfer pricing and intercompany debt matters. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals before the Internal Revenue Service, mediation involving the Appeals division of the IRS, and litigation before the United States Tax Court. Recognized by Chambers USA each year from 2006 through 2016, Scott is described as "a talented litigator and corporate advisor" who wins the confidence of clients with "extraordinary communication skills" combined with "broad and deep experience" and he is "recommended for his spot-on judgment and analysis," "his responsiveness and strategic thinking" and his "ability to anticipate issues before they arise." Recently, Scott led the Mayer Brown team that filed 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco International and related companies, which involved $3 billion in interest expense incurred from 1998 through 2000 plus an additional $6.5 billion in interest expense incurred from 2001 through 2007, and were settled for 8% of the amount in dispute. Scott holds a JD from Harvard Law School and an MBA from the Johnson Graduate School of Management at Cornell University.
Eduardo Maccari Telles is a Tax Litigation partner in the Rio de Janeiro office of Tauil & Chequer Advogados. Eduardo concentrates his practice in trial, litigation and arbitration, tax and administrative law. His clients include national and foreign companies, as well as governmental institutions, and he assists them in all types of dispute resolution for tax, civil, labor, intellectual property and environmental cases as well with tax and labor consulting. Apart from his tax specialization, Eduardo has experience in intellectual property litigation, actions relating to trademarks and patents, also in energy and insurance litigation as well, being responsible for coordinating the firm’s Brazil litigation practice. Eduardo has a master’s degree in Tax Law and serves as Coordinating Professor at Fundação Getúlio Vargas post-graduate tax courses. Since 2000, he has also served as a state attorney in the Attorney’s Office of the State of Rio de Janeiro. His other professional assignments have included work as a tax attorney with the National Institute of Social Security (1998-2000), as a legal counselor with Rangel, Penna da Rocha & Daiha Associated Attorneys (2000-2006), as external counsel for the Brazilian Institute of Municipal Administration (2000-2004) and as Treasury representative on the Taxpayer Council of the State of Rio de Janeiro (2004).
Emily Whittenburg is a Senior Tax Advisor at Shell Oil Company and President of the Tax Executives Institute - Houston Chapter in Houston, TX. In her current role for Shell, Emily is responsible for US state and federal tax shaping and legislative matters. She is involved in both US and global tax policy matters. Prior to joining Shell, Emily served as Tax Counsel for Waste Management, Inc. providing support for mergers and acquisitions and other corporate transactions. Before moving to an in-house tax role, Emily practiced corporate and transactional law in a law firm for several years. Her practice included representing clients in general corporate matters, financial transactions, commercial real estate and other transaction-based deals. Emily also spent seven years with the public accounting firms of Andersen and Ernst & Young serving clients as a Tax Manager. Emily is active in a number of taxpayer associations, including holding Board seats on the Texas Taxpayers & Research Association and the California Taxpayers Association. She also serves on the Tax Committee of several industry trade associations on behalf of Shell. Emily is currently serving as the TEI-Houston Chapter President and Co-Chair of TEI’s Sub-Committee on Emerging In-House Tax Professionals.
A select numbers of rooms have been reserved for the group at the discounted price of $229/night. Please use this link to book your accommodations.
Mayer Brown is a global legal services firm advising clients across the Americas, Asia and Europe. Our geographic strength means we can offer local market knowledge combined with global reach. We are noted for our commitment to client service and our ability to assist clients with their most complex and demanding legal and business challenges worldwide. We serve many of the world's largest companies, including a significant proportion of the Fortune 100, FTSE 100, DAX and Hang Seng Index companies and more than half of the world's largest banks. We provide legal services in areas such as banking and finance; corporate and securities; litigation and dispute resolution; antitrust and competition; US Supreme Court and appellate matters; employment and benefits; environmental; financial services regulatory & enforcement; government and global trade; intellectual property; real estate; tax; restructuring, bankruptcy and insolvency; and wealth management.
Mayer Brown’s global Tax practice consists of approximately 140 lawyers in offices around the world and covers every aspect of corporate, partnership and individual taxation in the United States, Europe, Brazil and Singapore, including taxation of domestic and cross-border issues at the national, state and local tax levels. The firm represents some of the world’s leading businesses in a wide range of matters including transactions, consulting and planning, administrative appeals and litigation, and transfer pricing. Mayer Brown’s Tax practice has received numerous accolades over the years, and was named “Tax Practice Group of the Year” by Law360 in 2015. The firm also was named “Tax Controversy Team of the Year” in the Legal 500 United States Awards 2015 and 2014. In addition, Mayer Brown was named “North America Tax Disputes Firm of the Year” at International Tax Review’s 2015 Americas Tax Awards.
Kelly S Mathews LLC (KSMLLC) specializes in volume-based US state and federal motor fuels tax compliance, consulting, and software implementation services. Our commitment to this specialty area provides a depth of knowledge in the motor fuels tax area not typically found in other accounting, law, or consulting firms. Visit our Services page for more information about how we can assist you.
Ryan is an award-winning global tax services firm, with the largest indirect and property tax practices in North America and the seventh largest corporate tax practice in the United States. With global headquarters in Dallas, Texas, the Firm provides a comprehensive range of state, local, federal, and international tax advisory and consulting services on a multi-jurisdictional basis, including audit defense, tax recovery, credits and incentives, tax process improvement and automation, tax appeals, tax compliance, and strategic planning. Ryan is a three-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA) for its commitment to world-class client service. Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryan’s multi-disciplinary team of more than 2,100 professionals and associates serves over 12,000 clients in more than 40 countries, including many of the world’s most prominent Global 5000 companies. More information about Ryan can be found at ryan.com.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)