The prospects for tax reform in 2017 are unclear but no one doubts that the final form of these changes will have a significant impact on all energy companies. CFOs and Tax VPs must remain vigilant and informed on ways to prepare for tax reform and maximize value. In response, Bloomberg BNA and Mayer Brown, are hosting the 4th Annual Energy Tax Conference: Maximizing Value, to help energy company finance and tax executives add incremental value to their organizations’ bottom line.
This must-attend event featuring government officials, policy makers, industry leaders and advisors will cover the status of tax reform, repatriation tax planning, tax reform planning, implementation of BEPS, transfer pricing, tax controversy issues, Latin American tax issues, and more.
The conference will also feature, the Houston TEI Chapter, a special CFO and VP Tax Roundtable session, where panelists will discuss aspects of tax reform, managing risk, working with other parts of their organizations, and how tax can support the company in maximizing value.
Day One: September 25, 2017
8:30 AM – 5:30 PM
Networking reception to follow.
Day Two: September 26, 2017
9:00 AM – 4:00 PM
Four Seasons Hotel
1300 Lamar Street
Houston, TX 77010
Earn up to 15.0 CPE or CLE credits
8:00 – 8:30 AM Breakfast and Registration
8:30 – 8:50 AM Keynote Address: The Prospects for Corporate Tax Reform
8:50 – 9:50 AM Tax Policy Under the New Administration and the Status of Tax Reform
The likelihood of business tax reform legislation in 2018 is high. Both President Trump and the House of Representatives Blueprint have proposed sharp cuts in corporate tax rates, rewriting the US international and cross-border tax rules, and eliminating business deductions and credits. While many proposals, such as rate cuts, would apply broadly across industries, various proposals would be of particular interest to the energy industry – including deemed repatriation, repeal of the corporate AMT, the elimination of Section 199, the possible elimination of the interest deduction, and the highly-charged issue surrounding proposed border adjustments. This panel will discuss the politics surrounding the reform and the likelihood of the various aspects of the proposals getting passed.
Moderator: Warren Payne, Senior Tax and Trade Policy Advisor, Mayer Brown, Washington, DC
9:50 – 10:50 AM Repatriation Tax Planning
It is widely expected by the tax community that a one-time deemed repatriation of foreign profits will be included in the tax reform package in connection with the transition to a territorial tax system. The House Blueprint taxes unrepatriated earnings held in cash or cash equivalents at a tax rate of 8.75% and the remainder at a tax rate of 3.5% which would payable over eight years. This panel will discuss several planning ideas to minimize the tax resulting from a deemed repatriation.
Moderator: Lewis Greenwald, Partner, Mayer Brown, New York
10:50 – 11:00 AM Break for Refreshments
11:00 – 12:00 AM No Regrets Tax Reform Planning Ideas
The natural reaction to a proposed corporate rate reduction is for US companies to accelerate US tax deductions and defer US taxable income. Other reform proposals such as elimination of the interest deduction will cause a necessary shift to how companies are currently structured around intercompany debt. This session will discuss ideas to deduction acceleration or income deferral items (e.g., depreciation methods, expensing methods, UNICAP, fixing bonus liabilities) and how to plan for the elimination of the interest deduction.
Moderator: Ed Osterberg, Partner, Mayer Brown, Houston
12:00 – 1:00 PM Luncheon
1:00 – 1:30 PM Keynote Address: The Geopolitics of Oil from 10,000 Feet
1:45 – 2:45 PM Implementation of BEPS
Energy companies continue to grapple with how to implement the OECD BEPS project action plans, including country-by-country reporting during the ‘gap’ year, hybrid entities given the proposed US 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 US, European, and foreign tax environments. The audience will hear from US Government representatives, industry, and advisory firms on how to adapt to the changing tax landscape.
Moderator: Clifford Mangano, Director of Global Transfer Pricing, Diamond Offshore Drilling, Houston
2:45 – 3:45 PM Meeting US and Global Transfer Pricing Requirements
The country-by-country reporting (CbCR) requirements, and various court cases have created new challenges for global energy companies as they work to meet their global transfer pricing requirements. Well-defined transfer pricing policies and strongly-developed local, master and CbCR documentation will assist companies in navigating the uncertainties created by the BEPS action plans and the US Treasury’s CbCR regulations. The audience will learn the latest developments affecting US taxpayers and practical tips on how to address their company’s changing transfer pricing needs.
Moderator: Scott Stewart, Partner, Mayer Brown,Chicago, IL
3:45 – 4:00 PM Break for Refreshments
4:00 – 5:30 PM CFO & VP Tax Roundtable (In conjunction with the TEI Houston Chapter)
With tax reform developments having a significant impact on the energy industry, how are CFOs and their VPs of Tax readying themselves to legislation as it moves through Congress and aligning their businesses with pre-reform planning? This moderated roundtable will provide an open and candid 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 on how the tax department should support the company in maximizing its value in this new era.
Moderator: Emily Whittenburg, Senior Tax Adviser, Tax Policy & Government Relations, Shell Oil Company, Houston
5:30 PM Cocktail Reception, Four Seasons Hotel
8:30 – 9:00 AM Breakfast
9:00 – 10:00 AM How to Approach Defendable Tax Planning
Energy companies are consistently investigating ways to become more tax efficient through internal restructuring. Because internal restructurings are usually transformative for the organization, these transactions draw the attention of IRS and the company’s financial auditor. This panel will discuss how to approach these transactions to ensure that the tax reporting will sustain scrutiny by IRS and/or the financial auditor. Some of the items discussed will include tax opinions, privilege, the use of pre-filing agreements, ruling requests, etc.
Moderator: Gary Wilcox, Partner, Mayer Brown, Washington, DC
10:00 – 10:30 AM Break
10:30 – 11:30 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 on which the IRS is focused 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: Shawn O’Brien, Partner, Mayer Brown, Houston
11:30 – 1:00 PM Luncheon
1:00 – 2:00 PM Six Things All Energy Industry Tax Executives Should Know About State Tax
Added together, state income taxes, sales taxes, excise taxes, and property taxes can match or exceed an energy company's federal tax burden. Whether your company has a dedicated state tax team or not, there are a number of issues everyone should be aware of to help your company better plan for, and when possible reduce, state tax exposure.
Moderator: Leah Robinson, Partner, Mayer Brown, New York
2:00 – 3:30 PM Latin American and Other International Developments
While we await tax reform in the United States, other countries have initiated their own versions of tax reform, notably in the implementation of the BEPS action items and the adoption of regimes addressing controlled foreign corporations, diverted profits and general anti-avoidance rules. The need for tax revenues has forced countries to identify alternative ways to collect revenue from multinational companies, particularly those in the energy sector. BEPS has encouraged this trend by promoting measures such as the expanded concept of a permanent establishment and by facilitating adoption of the BEPS proposals through the medium of the multilateral instrument. Particularly acute is the effect of these initiatives in Latin American countries with their complex tax systems, their proliferation of tax compliance rules, and the absence of timely administrative and judicial review. These developments will force multinational companies to change their approach to international tax planning. This session will provide an update on these and other developments and the best tax practices for dealing with them.
Moderator: Ivan Tauil, Partner, Tauil & Chequer associado a Mayer Brown LLP, Rio de Janeiro
3:30 PM Closing Remarks
Kaustuv Basu is a reporter covering Congress for Bloomberg BNA, where he writes on the intersection of tax policy and politics.
Most recently, he has focused on tax reform efforts on the Hill, including the House GOP’s tax reform blueprint and tax overhaul ideas from President Donald Trump’s administration. He talks to a wide array of current and former lawmakers and staff, lobbyists and thought leaders for his articles.
Basu previously worked for Tax Analysts and Gannett. He has appeared on Bloomberg Radio, and won journalism awards from the Society of Professional Journalists, the Florida Press Club and the Education Writers Association.
He holds a master’s degree in journalism from the University of Southern California’s Annenberg School for Communication and Journalism.
Todd Behrend is a Principal in the Atlanta International Tax and Transfer Pricing practice at Ryan. Todd specializes in international tax with a focus on increasing shareholder value through the development of proactive international tax solutions for both U.S. and foreign-based multinational companies. Prior to Ryan, Todd was a partner in a big four firm, serving multinational clients throughout the world.
Todd is a frequent speaker on international tax matters for clients and on a regular basis at Georgia State University. Todd is a member of the IFA USA advisory board and a past regional vice president.
Patrick Berrigan leads the International Tax practices in the Greater Houston area as well as the North Texas/Dallas office. He oversees the our Houston market’s Global Solutions Team, the alignment of our International Tax, Transfer Pricing and M&A groups toward targeted solutions for multinational companies. Patrick joined PwC in 1983 in our Chicago office. He was admitted to the partnership in 1996 and moved to the Houston office in 1998.
Patrick has specialized in International Taxation since 1983 and specializes in serving the international tax needs of both U.S. and foreign companies. Patrick has assisted numerous clients establish their foreign holding company structures; U.S. inbound leasing operating strategies; entrepreneur/principal structures; host country tax minimization structures; and cash repatriation planning. Patrick has been a pioneer in our firm’s service to company’s considering an “inversion” transaction – either self-directed or as part of a non-U.S. merger. He has worked with many company’s achieve operational efficiencies through realignment of assets and operations, including asset extraction planning following inversion transactions. Patrick founded our firm’s solutions strategy group focusing on Overall Foreign Losses (OFL) and interest expense apportionment planning.
Pat has a Bachelor's degree in Accounting from University of Notre Dame, and a Master's of Science in Taxation from DePaul University. He is a member of the AICPA, the Missouri State Board of Accountancy, and the Texas State Board of Public Accountancy.
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 estaterelated 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.
Stephen Comstock is currently the Director of Tax & Accounting Policy for the American Petroleum Institute. His responsibilities cover coordination and managing tax issues impacting the industry as well as developing API’s policy positions on trade, accounting and cyber issues.
Prior to joining API, Stephen was a tax attorney with ExxonMobil in their Tax Department and provided planning advice for various projects in their Upstream, Downstream and Chemical operations. He is currently an adjunct professor at Georgetown Law School and was formerly chair of the Energy and Environmental Taxes Committee of the American Bar Association’s Tax Section. He received a BA from the University of Texas and a JD from George Washington University.
Katie Devinney is a State Tax Law Editor at Bloomberg BNA. She contributes to the Sales Tax Slice blog and works on maintaining and upgrading BBNA’s state tax products. Katie received her J.D. from Georgetown University Law Center and her B.F.A. from the University of Central Oklahoma.
With over 28 years of tax controversy experience, Steve specializes in advising and representing clients before the Internal Revenue Service in audits conducted by the IRS Large Business and International Division. Steve also specializes in preparing protests and representing clients before the Internal Revenue Service Office of Appeals. Steve has broad experience with corporate, partnership and international issues with significant experience in transfer pricing, R&D credits, accounting methods, Global High Wealth audits, cooperatives under Subchapter T, corporate reorganizations, substance vs. form issues, debt/equity determinations, fixed assets/cost segregation, information reporting and withholding and oil and gas issues. Steve also has significant experience with IRS Examination and Appeals procedures, domestic and international information gathering, closing agreements and statute of limitations issues.
Prior to joining EY, Steve was an attorney with the Internal Revenue Service Office of Chief Counsel for nine years. As a Senior Attorney with Houston District Counsel, he advised the Houston District’s Coordinated Examination Program (CEP) regarding technical and procedural issues. Steve spent a significant amount of time assisting CEP agents in developing the factual and legal aspects of corporate, partnership and international issues. In addition, Steve provided advice to the Houston Appeals Office. He was also responsible for litigating cases in the United States Tax Court.
Steve is a graduate of Wesleyan University and holds a Juris Doctor from SUNY Buffalo and a Masters of Law in Tax from the University of Houston. Steve is a member of the State Bar of Texas and the New York State Bar. He has been a speaker at numerous continuing education programs including Tax Executives Institute, American Petroleum Institute Tax Forum, Denver University Tax Institute, Tulane Tax Institute, State Bar of Texas Advanced Tax Law Course and Petroleum
David Ernick is a Principal in the Transfer Pricing Practice of PricewaterhouseCoopers’ (PwC) Washington National Tax Services office. Prior to joining PwC, David was Associate International Tax Counsel at the U.S. Treasury Department. While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters. He also represented the United States as a delegate to the Organization for Economic Cooperation and Development (OECD) Working Party No. 6 on Transfer Pricing, and served as the Chair of its Special Session on Business Restructurings. David was the principal staff attorney for transfer pricing matters at Treasury, and advised on every significant guidance project in this area released by Treasury and the OECD during his tenure, including the final regulations on cost sharing arrangements and controlled services transactions. Prior to joining Treasury, David practiced as a tax associate at Cravath, Swaine & Moore in New York and at WilmerHale in Washington. He has clerked at the U.S. Tax Court and the U.S. Court of Appeals for the Eleventh Circuit. He currently serves as an adjunct professor and teaches a course on transfer pricing in the Graduate Tax Program at Georgetown University Law Center. He is also a co-author of the 2014 Practising Law Institute's (PLI) Transfer Pricing Answer Book and a member of both the Bloomberg BNA Transfer Pricing Advisory Board and the Tax Management International Journal’s Panel of Leading International Tax Practitioners.
Carlos González Gamero is Administrator for Tax Legal Affairs (Hydrocarbons), unit responsible for issuing rulings, APAs, and performing Competent Authority functions in MAP cases for taxpayers within the scope of the General Administration for Hydrocarbons. Before joining the General Administration for Hydrocarbons, he worked in the Transfer Pricing Audit Unit of the SAT Large Taxpayers Division, performing audits to taxpayers of the Oil & Gas industry and the Energy sector. Carlos is a delegate representing Mexico in the Working Party 6 of the Committee on Fiscal Affairs (taxation of Multinational Enterprises) and the FTA MAP Forum of the Organization for Economic Co-operation and Development (OECD).
Lucas Giardelli is a Tax Transactions & Consulting associate in Mayer Brown’s New York office. His practice is focused on international tax planning (including controlled foreign corporations/Subpart F income, tax-efficient reorganizations, cross-border financing, IP planning, individual tax planning) and corporate tax matters, advising clients on the tax aspects of mergers, acquisitions, financing arrangements and other transactions. Prior to joining Mayer Brown in 2012, Lucas practiced tax law at a leading law firm in Argentina.
Jim Ginty is a Partner in PricewaterhouseCooper’s International Tax Services group in Houston. He has over thirty years of experience of providing international, corporate and financial product tax consulting advice to U.S. and foreign-based multinationals in the oil and gas, energy, manufacturing and service industries. The majority of his career has been with PwC, but he also has seven years of experience in industry.
Jim worked in the Hong Kong office of PwC for two years. He received a B.A. in Mathematical Sciences (magna cum laude) and a Master of Accounting from Rice University. He is a CPA.
Lewis J. Greenwald is a Tax Transactions & Consulting partner in Mayer Brown's New York office. His practice is focused on providing international tax planning for multinational clients including, but not limited to:
He has almost 30 years of tax law experience. He is the former regional vice president of the New England region of The International Fiscal Association (IFA). He is on the Board of the National Foreign Trade Council (NFTC) and on the Board of Advisers for the Journal of International Taxation. He speaks frequently and has written numerous articles.
Steve Hayes currently serves as Senior Vice President‐ Tax & Asset Management for the Transocean group and is based in Switzerland. He currently serves as the Chairman of the Tax Committee for the International Association of Drilling Contractors (“IADC”).
Steve joined Transocean in 2005. He previously served as Vice President, Tax, for Unocal Corporation. He also previously served in various management positions with ARCO. He started his career in public accounting with Arthur Andersen. He is a certified public accountant and holds a Masters of Professional Accounting degree (Taxation) from the University of Texas at Austin, Texas, and a Bachelors of Business Administration (Accounting) from Texas Christian University in Fort Worth, Texas.
Steve has represented IADC and the drilling sector in dialogue regarding various tax reform and policy matters with the OECD, EU and numerous different countries, including the U.S., UK, Norway and Egypt.
Charlie joined KBR as Assistant Vice President of Tax Operations in January 2016. Effective November 1, 2016, he became Head of Tax.
He has more than 20 years of experience in tax and corporate financial accounting experience in the engineering and construction and chemical manufacturing businesses with multinational companies. Prior to joining KBR he was Assistant Controller of Albemarle Corporation where he headed the acquisition accounting process for its $6 billion acquisition of Rockwood Holdings, Inc. Before Albemarle, he was a Senior Director of Tax Accounting for The Shaw Group Inc. He led the acquisition accounting for income taxes following the $3 billion acquisition of Shaw by CB&I and also worked in the transition of the tax functions following the acquisition. Prior to his industry experience, he spent seven years in public accounting.
He earned a Bachelor of Science degree in Accounting from Southeastern Louisiana University in Hammond, LA. He is a licensed Certified Public Accountant in Louisiana.
Scott A. Hodge is president of the Tax Foundation in Washington, D.C., and is recognized as one of Washington’s leading experts on tax policy, the federal budget and government spending. During his tenure, the Tax Foundation has become one of the most influential organizations on tax policy in Washington and in state capitals. He led the development of the Tax Foundation’s most successful programs, the Taxes and Growth Dynamic Tax Modeling project and the State Business Tax Climate Index; two projects that have changed the terms of the tax debate at the federal and state level.
Over the past 25 years Scott has been a leader in many successful efforts to change public policy. During the 1990s, he helped design the major tax components for the Contract with America. These tax cuts were the eventual centerpieces of the 1997 tax bill and the Bush tax cuts in 2001 and 2003.
Scott has written and edited three books on the federal budget and streamlining the government and has authored over 100 studies on tax policy and government spending. He has also authored dozens of editorials and opinion pieces for publications such as The Wall Street Journal, The Washington Post, USA Today, The New York Post and The Washington Times. Hodge has conducted over 600 radio and television interviews—including NBC Nightly News, CBS Nightly News, CNN, Fox Network, Hardball with Chris Mathews, and C-SPAN.
Scott began his career in Chicago where he helped found the Heartland Institute in 1984. Before joining the Tax Foundation, Scott was Director of Tax and Budget Policy at Citizens for a Sound Economy. He also spent ten years at The Heritage Foundation as a fellow analyzing budget and tax policy. He holds a degree in political science from the University of Illinois at Chicago.
Mr. Jenn joined the Office of the International Tax Counsel in the Treasury Department's Office of Tax Policy in January 2012. At Treasury, he focuses on a wide range of international tax legal and policy issues, including subpart F, foreign currency issues, transfer pricing, digital economy and cloud issues, and cross-border reorganizations. He is a U.S. Treasury delegate to OECD’s Working Party 6 on Transfer Pricing, which has responsibility for the development of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and is Co-Chair of the OECD’s Task Force on the Digital Economy.
Mr. Jenn earned his B.A. and M.A. (Economics) at Northwestern University and his J.D. at Yale Law School. Prior to joining Treasury, Mr. Jenn worked on international tax issues at a law firm in Washington, DC, and served at the Council of Economic Advisers (2001-2003) and in the U.S. Senate on the Chairman’s staff of the Joint Economic Committee (2003-2004).
Elena is the Director of Transfer Pricing and Valuation Services. She has over 17 years of transfer pricing, valuation, and general quantitative analysis experience, including over 16 years with Mayer Brown. Elena has performed transfer pricing and valuation analyses for purposes of advance pricing agreements (APAs), tax planning, contemporaneous documentation, audit defense, and litigation for clients that range from some of the largest multinational enterprises in the world to privately-held companies in a wide range of industries that include heavy machinery manufacturing, software, oil & gas, automotive manufacturing, distribution, electronics, pharmaceuticals, consumer products, services, shipping, agricultural production, financial institutions and products, leisure travel, and Internet.
Elena has worked with a number of large U.S. and foreign-parent multinational companies on all aspects of their APA requests and negotiations, including an automotive OEM, an industrial conglomerate, an industrial products company, a global services provider, a multinational bank, and a pharmaceutical company, among others. Analyses conducted by Elena have been used to reach agreement with the IRS or other tax authorities at the field examination or appeals levels, and have been employed in successful competent authority negotiations.
Elena has successfully developed innovative solutions to handle a wide variety of complex transfer pricing issues including foreign exchange fluctuation, location savings, and excess manufacturing capacity. Elena has been engaged in numerous projects that involve transfer pricing of intangible property, including the development of royalty rates for licensed intangibles, valuation of intellectual property for purposes of corporate restructuring, and economic modeling of returns on investment for purposes of cost-sharing arrangements.
Jim Krane, Ph.D., is the Wallace S. Wilson Fellow for Energy Studies at Rice University’s Baker Institute. His research addresses the geopolitical aspects of energy, with a focus on the Middle East and the OPEC states and their political and economic strategies. His scholarly articles focus on energy subsidies and demand, as well as internal politics in exporting states. He teaches classes on energy policy and geopolitics at Rice University.
His research grants include awards from the Qatar National Research Fund, the Dubai School of Government and Cambridge University. He is the author of the 2009 book “City of Gold: Dubai and the Dream of Capitalism,” which received warm reviews from the Financial Times, Bloomberg News, the Guardian, the Daily Telegraph and the New York Review of Books, among others.
Krane is a longtime journalist who reported from the Middle East for more than five years. As the Gulf correspondent for the Associated Press in Dubai, he covered the economic boom and developments that transformed the emirate into one of the world’s most globalized cities. He also wrote about the Gulf region for the Wall Street Journal, the Economist Intelligence Unit, the Financial Times and many other publications. Krane was based for more than a year in Iraq, where he covered the aftermath of the U.S. invasion and ensuing insurgency for AP. Previously, Krane was an AP Business writer in New York, responsible for technology news. He is the winner of several journalism awards, including the 2003 AP Managing Editors Deadline Reporting Award, received for his coverage of Saddam Hussein’s capture in Iraq. Krane is a member of Cambridge University’s Energy Policy Research Group, where his Ph.D. studies took place. He holds an M.Phil. in technology policy from Cambridge University’s Judge Business School and a master’s in international affairs from Columbia University.
Lynn is a Managing Director in charge of Transaction Services and Taxation for Opportune LLP in Houston, Texas. He has over thirty years of corporate tax and accounting experience with Big Five public accounting and similar professional services firms.
Prior to joining Opportune, Lynn served clients in both relationship and specialty roles ultimately as a partner at Arthur Andersen and Deloitte Tax, and as a Managing Director at Alvarez & Marsal. He has advised both public and private companies in the oil & gas, oilfield service, public utility, and service industries. Lynn has significant experience in mergers and acquisitions, roll-ups, spin-offs, IPOs, lease and project finance, and troubled debt restructurings and bankruptcies. His assignments include engagement and transactional responsibility for tax planning and compliance matters, accounting for income taxes, leases, transactional due diligence, representation before the Internal Revenue Service and the Securities and Exchange Commission, valuation engagements, and expert testimony before bankruptcy and other courts.
Lynn was a panelist before the FIN 48 working group at FASB, and has been a frequent presenter on contemporary tax and accounting topics before groups such as the Houston Bar Association, the Oklahoma State University Oil & Gas Accounting Conference, the AICPA Energy Conference, the Tax Executives Institute, and the University of Mississippi Accountancy Program. He was a member of firm wide teams specializing in Subchapter C (corporate taxation), leasing, ASC Topic 740, and the opinion committee at Andersen. He received his B.B.A. in accountancy from the University of Mississippi, and became a Certified Public Accountant in 1979. Lynn is a member of the American Institute of Certified Public Accountants, and holds active CPA licenses in the states of Mississippi and Texas.
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 U.S. 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 and the International Association of Drilling Contractors. He has a Ph.D. in Mineral Economics from the University of Arizona.
Barbara is a transfer pricing advisor with more than twenty years of experience in both the private sector and the Internal Revenue Service; Barbara advises multinational enterprises regarding a wide range of transfer pricing matters.
Barbara served as a Competent Authority Analyst and APA Team Leader from 2009-2013 at the Internal Revenue Service U.S. Competent Authority office and Advance Pricing and Mutual Agreement Office. Her duties included negotiating the settlement of numerous double tax cases and advance pricing agreements with tax authorities from Japan, India, Denmark, Belgium and Canada
As a tax advisor both at a global law firm and at Big 4 accounting firms, Barbara has advised multinational enterprises regarding planning and development of a global transfer pricing strategy, documentation, cost sharing arrangements, global restructuring, and treaty-based dispute resolution, i.e., competent authority assistance and advance pricing agreements. With her strong background in technical writing and analysis, Barbara has published articles on a wide range of transfer pricing topics, including advance pricing agreements, mutual agreement procedures, and transfer pricing documentation (including country-by-country documentation). She has been a speaker at numerous tax conferences and seminars, including meetings sponsored by the Tax Executives Institute, the American Bar Association, the International Fiscal Association, and Bloomberg BNA
Barbara has a Master of Laws in Taxation from Georgetown University Law Center, a J.D. from the University of Maine School of Law, a B.A. from Boston College, and an Advanced Certificate, Graduate School of Conflict Analysis and Resolution, George Mason University.
Tax Lead of U.S. Direct Tax Filing & Reporting Manager for Shell Oil Company. As lead, principally charged with assuring all U.S. tax filings and financial reporting of tax matters is performed on a timely and accurate manner. Pursuant to Shell's global practice of a dispersed finance community, has significant involvement with Shell's Finance Operations in India. Previous to his current role, Paul served as the Tax Lead for Shell's State Direct Audit, Property Tax, and SALT litigation groups, ensuring the three teams are effectively providing solid SALT advice while focusing on using limited resources to deliver high value to Shell's business units. Advice goes out to both upstream and downstream operations, as well as general corporate operations. Work includes managing relationships with the several tax authorities with which Shell does business, with emphasis on California, Louisiana, Texas and Washington.
Former Associate Attorney General in the Taxation Division for the Texas Attorney General, having litigated substantial cases on behalf of the Texas Comptroller for five years. Prior to that, was a CPA with Grant Thornton and associate with Baker & McKenzie (international business and tax controversy), Vinson & Elkins (international tax and transfer pricing), and Senior Counsel for Chamberlain Hrdlicka where I focused on State and Local Tax (SALT) matters for business, while also supporting commercial litigation and federal tax matters.
Specialties: State and local tax (SALT), property tax (including EP), federal tax planning for corporations and partnerships, and tax controversy work including counsel in tax audits and representation before the local tax authorities.
Wade leads the Houston Tax Controversies practice and is Deloitte’s Tax Controversy Services Regional Competency Leader for the Central-South region of the U.S. He has extensive tax controversies experience over a broad range of clients including several Fortune 100 energy companies, oil-field services companies, transportation companies, real estate management companies, engineering and construction firms, retailers, airlines, investment funds, and high-wealth individuals, estates, and trusts.
Wade’s Tax Controversies experience includes handling IRS case management for primarily LB&I cases at both the Examination and Appeals levels. In addition, Wade regularly provides advice on general IRS practice and procedure issues and assists clients with penalty abatements. In his role, Wade has assisted clients with voluntary compliance submissions to the IRS related to withholding tax issues. He has also represented many clients during withholding tax examinations and has helped companies implement new tax and accounting processes and procedures to facilitate compliance with the withholding rules.
Mr. Mintz is Vice President and Chief Tax Officer of Kinder Morgan, one of the largest energy infrastructure companies in North America.
Mr. Mintz joined Kinder Morgan in June of 2006 and oversees administration of the corporate and partnership tax planning, compliance and reporting functions for the company.
Prior to joining Kinder Morgan in 2006, Mr. Mintz served as Senior Vice President - Tax at Centex Corporation, a Fortune 250 homebuilder and financial services company. In addition, he served as Managing Director - Corporate Tax at Enron Corporation, Tax Partner at Bracewell & Giuliani and Senior Tax Attorney at Exxon Corporation.
Mr. Mintz holds an LLM from New York University School of Law, a J.D. from Boston University School of Law and a B.S. from the University of Pennsylvania.
Kinder Morgan owns an interest in or operates 84,000 miles of pipelines and 155 terminals. The company's pipelines transport primarily natural gas, refined petroleum products, CO2 and crude oil and its terminals store, transfer and handle such products as gasoline, ethanol, coal, petroleum coke and steel.
Christina Moss is a Director located in PwC’s Greater Houston office and part of the National Tax Services, US Tax Controversy and Regulatory Services Group. Christina currently assists clients with IRS examinations on domestic, international and withholding tax issues. Christina has extensive experience and expertise in IRS practice and procedure and controversy experience with IRS Appeals, Tax Court, and various IRS alternative dispute resolution programs, including Compliance Assurance Process (CAP), Fast Track Settlement, Post Appeals Mediation, pre-filing agreements, accelerated issue resolution (AIR), and closing agreements.
Prior to joining PwC in March 2013, Christina spent twenty one years with the IRS Office of Chief Counsel’s office in Houston, Texas. During her tenure, Christina held various positions including Special Trial Attorney from 2007-2013, where she served as the lead trial attorney responsible for preparation and presentation at trial of the most significant and complex issues involving some of the largest multinational corporations within LB&I, including various transfer pricing and other international tax disputes, before the United States Tax Court.
Christina also has extensive international experience and expertise with transfer pricing examinations, Advance Pricing Agreements, permanent establishment issues, foreign tax credit matters, 965 repatriation, and ETI matters. She served as Industry Counsel for Section 965 Tier I issue, International Issue Counsel for Foreign Tax Credit Matters and Subpart F, and International Field Counsel from 2001-2007. She also has over fifteen years of experience working on energy sector examinations.
Christina received the IRS Commissioner’s Award in 2001 for her outstanding work on a very complex corporate bankruptcy examination. She earned her J.D. degree from Washburn University School of Law (cum laude) and her undergraduate degree from Wichita State University (magna cum laude).
Paul Mundwiller is a Tax Partner at KPMG with more than 24 years of public accounting experience. He currently serves the oilfield service and industrial sectors in providing tax consulting services. Paul is responsible for a broad range of US multi-national and foreign-owned clients doing business as consolidated groups, single entities or joint ventures, and has extensive experience with a wide range of complex tax matters relating to his clients’ business. Paul advises on acquisitive and restructuring transactions and provides both tax planning and compliance in several industries. He has gained a deep knowledge of global tax provision issues through working with KPMG’s multinational audit clients on ASC 740 matters
Bashir Nangoli is the CFO for Tenaris North America. He joined Tenaris two years ago and has over 20 years of experience in the oilfield manufacturing & service industry. In his current role as CFO he is a strategic advisor and business partner to the President, Global CFO and other key executives. He leads all the financial functions driving tactical, business & financial strategies to achieve and exceed financial goals.
Prior to Tenaris, Bashir began his career in the oilfield with Schlumberger in the fall of 1996 in Dubai. Over the next 18 years, he worked in Middle East Asia, Far East Asia and the United States in California, Louisiana and Texas in various roles as Controller, Reporting Manager, Internal Audit Manager and M&A. After Schlumberger he was with Weatherford for 15 months as Global Controller for their Production group. He has hands on experience with FP&A, bidding, budgeting, M&A, business divestiture & reengineering, automation, outsourcing, risk management, manufacturing, supply chain and tax planning. Bashir has successfully led multi-national teams in challenging environments/countries with complex legal and fiscal protocols. Bashir has a Bachelor's degree in Accounting with specialization in Taxation from Bangalore University and an ACA certification from the Institute of Chartered Accountants of India.
Fred Nicely is a Senior Tax Counsel at COST. His role as Senior Tax Counsel extends to all aspects of the COST mission statement: “to preserve and promote equitable and nondiscriminatory state and local taxation of multijurisdictional business entities.” Before joining COST, Fred served in the Ohio Department of Taxation for four years as Deputy Tax Commissioner over Legal and for the prior seven years as the Department’s Chief Counsel. Fred’s responsibilities at the Department included testifying before legislative committees, participating as an alternative delegate for Ohio at Streamlined Sales Tax Project meetings, and reviewing legal documents issued by the Department, including deciding the merits of filing an appeal. He is a frequent speaker and author on Ohio’s tax system and on multistate tax issues generally. Fred also has extensive experience in public utility tax law, having served as an administrator of the Department’s public utility tax division. Fred’s undergraduate degree in psychology (with a concentration in accounting) is from the Ohio State University. He obtained his MBA and JD from Capital University in Columbus, Ohio.
Victor Nieto is a tax attorney with over twenty years of experience in international tax planning, compliance, domestic and international tax controversy, and tax technology. Victor worked at two major accounting firms prior to going in-house. He has a JD from Notre Dame Law School and is a member of the Texas State Bar, the American Bar Association, and the Tax Executives Institute.
Shawn O'Brien is a Tax partner who 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 v. equity issues, international withholdings, advance pricing agreements, "tax shelter" disallowances, research and development tax credits, excise taxes, changes in accounting methods, Offshore Voluntary Disclosure Program (OVDP), Streamline Program, Domestic Production Activities Deduction (section 199), Micro-Captive Insurance, related party transactions, basket options transactions, repatriation structures, inbound distributors, alternative minimum tax (AMT) preference items, and foreign tax credits.
Shawn is particularly focused on a variety of tax issues facing the energy industry including tax controversy, joint ventures, restructuring, acquisition and disposition of energy assets. Shawn served as Chair of the Energy and Natural Resources Committee of the State Bar of Texas Tax Section from 2011 to 2013.
Jason Osborn is a Tax partner in the firm’s Washington DC office. He provides sophisticated transfer pricing and international tax advice to multinational clients in wide range of industries, including financial institutions, pharmaceuticals, chemicals, software, automotive, consumer products, energy and transportation.
Jason re-joined Mayer Brown in 2013 after holding transfer pricing-related positions with Internal Revenue Service (“IRS”) from 2008-2012, initially as a team leader in the Advance Pricing Agreement (“APA”) Program and subsequently as a manager in the transfer pricing branch of the Office of Associate Chief Counsel (International). Leveraging this IRS experience, Jason brings to the table a unique and insider’s perspective in advising clients on complex transfer pricing matters and negotiating APAs. Prior to his IRS service, Jason was a senior Tax associate at Mayer Brown focused on transfer pricing matters.
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-U.S. partners; and inbound investment into the United States by non-U.S. 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.
Warren S. Payne is a senior advisor in Mayer Brown's Washington DC office and a member of the Tax, Government Relations & Public Law 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.
Warren served as a senior staffer to both the National Commission on Fiscal Responsibility and the Joint Select Committee on Deficit Reduction. In his role as Policy Director, Warren was responsible for working with Subcommittee Staff Directors to develop and implement the Committee's priorities and coordinated those efforts with House of Representative Leadership-serving as a key liaison with the Administration, the Senate as well as House Leadership. Originally, Warren served as one of the Committee's primary economists focused on trade policy, where he crafted the economic analysis behind the recent trade agreements with Colombia, Panama, Peru and South Korea.
Bruce manages international and foreign country reference publications for Bloomberg BNA, as well as advising various international news and notification publications. Before joining Bloomberg BNA, Bruce was an international specialist principal in the Washington National Tax Office of Deloitte Tax LLP for 28 years, and focused on cross-border acquisition, investment, and financing structures; deferral issues; and US and foreign tax issues of cross-border services organizations. Before joining Deloitte, he was a Senior Trial Attorney in the US Department of Justice’s Tax Division, focusing on cases involving international tax issues and foreign taxpayers.
Bruce received his B.A. in history from Yale University; J.D. and LLM (Tax) degrees from Georgetown University Law Center; and read post-graduate law at Oxford University. He is a member of the District of Columbia and Virginia Bars.
Leah Samit Robinson leads Mayer Brown’s State & Local Tax group and is a member of the Tax Transactions & Consulting practice. A partner in the firm’s New York office, she advises public and private business entities on state and local tax planning, controversy and litigation.
She provides national and state tax strategy and audit assistance for clients on a full range of tax matters, including nexus, combination and apportionment, and net operating loss issues. She is the co-author of the chapter on “Appeals” in State Business Taxes (Law Journal Press 2009).
She is particularly well-known for her advocacy in New York City and New York State, as well as for advising on the impact of the massive New York tax reform undertaken in 2014 and 2015. She was appointed to the New York City Department of Finance Commissioner’s Advisory Board (2014–present) as well as to the city’s Pass-Through Taxation Working Group (2014–2015), a think tank formed by the Department of Finance to assist with bringing reform to the city’s Unincorporated Business Tax. Leah has been a principal drafter of six reports issued by the New York State Bar Association Tax Section commenting on tax reform legislation and proposed draft regulations and one report issued by the New York City Bar Tax Section. She is the author of the “In a New York Minute” column published by State Tax Notes.
Leah is also well known for her advocacy in New Jersey tax disputes, covering income tax and sales tax matters. Leah was counsel or co-counsel in disputes related to New Jersey’s now-defunct throwout rule (Pfizer), taxation of extraterritorial income (IBM), treatment of limited partners (Preserve II), taxation of partnerships (Pulte Homes), apportionment of income from securitized loan portfolios (Capital One), and sales taxation of temporary help services (Labor Ready) and electricity distribution charges (Atlantic City Showboat). She has been appointed to the New Jersey Supreme Court Committee on the Tax Court (2017–2018 term) and authors the State Tax Notes column, “The Jersey Short—Everything You Need to Know about New Jersey Tax.” She is an editor of BNA’s Corporate Income Tax Navigator (New Jersey)
Victoria Sherlock is a Tax Managing Director in KPMG’s Houston’s office and is the Tax Controversy Practice Leader for the Southwest area (Texas, Oklahoma, Colorado and Louisiana). She has more than 30 years of experience in tax controversy matters and regularly represents corporate and other business clients before the Internal Revenue Service. She focuses on tax controversy matters including IRS audits and appeals involving complex domestic and international tax issues.
Victoria joined KPMG in the fall of 1998 to lead the Southwest Area’s Tax Controversy Services practice. The practice focuses on IRS examinations, appeals, and various alternative dispute resolution proceedings. Victoria advises clients on all aspects of IRS controversy matters and coordinates KPMG’s representation of clients before the IRS in the Southwestern portion of United States. She has special experience in handling oil and gas tax issues, accounting methods and credit issues, as well as transfer pricing matters.
Before joining KPMG, Victoria was a senior attorney with Houston District Counsel, IRS, where she was responsible for the development and litigation of major tax controversies. Victoria was actively involved in providing support and advice to large case examination teams on a wide variety of matters including corporate tax shelters, oil and gas issues, and transfer pricing issues.
In 1994, Victoria was appointed Special Counsel to the Department of Justice Tax Division in order to participate in the litigation of a major oil and gas issue in the U.S. District Court for the District of Delaware. As the result of her efforts in this case, She was awarded the Attorney General’s Special Contribution Award in October 1996.Before returning to the IRS in 1991, she was in private practice in Houston, Texas. Prior to 1986, Victoria was a trial attorney with the Department of Justice Tax Division in Washington, D.C. and Dallas, Texas, and a Senior Attorney Advisor with the IRS National Office.
Victoria is a frequent speaker at tax conferences including those sponsored by the State Bar of Texas, Texas Society of CPAs, Tax Executives Institute, and various local AICPA chapters.
Jennifer Stewart is Senior Vice President, Tax and Treasury and is currently fulfilling the duties of the Chief Financial Officer on an interim basis. She joined the company in 2010 as Vice President of Tax and was promoted to her current role in 2015. Prior to joining Southwestern, Ms. Stewart practiced law at Andrews Kurth Kenyon LLP and Shell Oil Company, and worked for 10 years in Ernst & Young’s national tax practice. She is an attorney licensed to practice with the State Bar of Texas and is admitted to the Bar of the U.S. Tax Court. Ms. Stewart holds a bachelor’s degree in Business Administration from the University of South Florida and a juris doctorate from the University of Houston Law Center.
Since joining Mayer Brown in 1989, Scott Stewart’s practice has focused exclusively on tax disputes, including transfer pricing issues arising under I.R.C. §482 and intercompany debt matters arising under I.R.C. §385. 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 2017, Scott is described as "a talented litigator and corporate advisor" who wins the confidence of clients with his "extraordinary communication skills," "professional demeanor" and "broad and deep experience." He is "recommended for his spot-on judgment and analysis," "his responsiveness and strategic thinking" and his "ability to anticipate issues before they arise." Chambers describes him as "easy to work with" and "very knowledgeable on the subject matter, attentive to client needs and quick to learn the client's issues and business." Chambers notes that he is "particularly adept at handling transfer pricing cases at all levels" and "frequently leads on market-defining transfer pricing disputes, often with multi-billion dollar outcomes."
Scott has extensive experience with deductibility of interest expense in related-party transactions, including debt-versus-equity characterization and "sham transaction" and "economic substance" issues, dating back to his involvement in the landmark Nestlé Holdings case during the 1990s. 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. The cases, which involved $3 billion in interest expense incurred from 1998 through 2000 and implicated an additional $6.5 billion in interest expense incurred from 2001 through 2007, were settled for 5% of the amount in dispute.
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 2016, 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.
Eduardo Maccari Telles is a partner in the Rio de Janeiro office of Tauil & Chequer Advogados. Eduardo concentrates his practice in trial, litigation and arbitration, tax and administrative law. He represents 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. Eduardo has experience in energy and insurance litigation as well, being responsible for coordinating the firm’s Brazil litigation practice.
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).
Mr. Teuscher joined Williams in March 2017. From 2009 to 2017 Louis was Vice President Tax for Talisman Energy Inc, a global oil & gas company and since 2006 he was Global Tax Director with Kraton Polymers Holdings (Houston). Prior to 2006 Mr Teuscher held several senior tax positions with Schlumberger in the U.S., Europe, and Asia.
Louis holds a U.S. Masters in Taxation from the University of Tulsa, as well as a European Masters in Taxation. He is a graduate of the Advance Management Program at Harvard Business School. Mr. Teuscher also serves on the board of the Master Limited Partnership Association (MLPA).
Chetan specializes in structuring international operations to minimize worldwide taxes and is familiar with the tax implications of cross border transactions, inbound structuring of operations for foreign multinationals, planning using financing techniques, foreign tax credit planning, IP migration and local country tax planning.
He has participated in post-merger integration projects for large multinational corporations and his experience includes effective tax rate planning, tax efficient movement of cash, interest expense apportionment, super holding company structures, inbound and outbound financing, inbound and outbound leasing structures, yieldco (foreign MLPs) structuring local country tax minimization, debt push down, inversions, inbound freeze structures, and quantitative analysis focused on foreign tax credit planning.
He has extensive experience working with three large US multinationals on inversion transactions and led the recent two inversions in the drilling sector.
He has significant experience in Section 861 Interest Expense Appointment (FMV Method) analysis and E&P Studies. His clients include an integrated super major oil and gas company, various oil field service companies and global chemical companies.
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.
Gary Wilcox is a partner in Mayer Brown’s Washington DC office and a member of the Tax Controversy and Transfer Pricing practices. Gary recently joined Mayer Brown, after serving as a co-leader of PricewaterhouseCoopers’ (PwC) US tax controversy practice. Previously, Gary led the tax practice at another international law firm. Prior to that, he served as the deputy chief counsel of the US Internal Revenue Service (IRS), where he was in charge of approximately 700 attorneys in the Office of Chief Counsel and had primary responsibility within the IRS for developing its positions on technical tax issues and the issuance of regulations and rulings.
Gary’s practice focuses on tax and transfer pricing planning, and tax controversies. Gary has been repeatedly recognized by the International Who’s Who of Corporate Tax Lawyers and the International Tax Review Tax Controversy Leaders Guide. Gary is a council director of the American Bar Association’s Tax Section and a fellow of the American College of Tax Counsel.
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Mayer Brown is a global legal services organization advising clients across the Americas, Asia, Europe and the Middle East. Our presence in the world’s leading markets enables us to offer clients access to 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, CAC 40, DAX, Hang Seng and Nikkei 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, arbitration, and other dispute resolution; antitrust and competition; US Supreme Court and appellate; employment and benefits; environmental; financial services regulatory and 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.
Ryan, an award-winning global tax services and software provider, is the largest firm in the world dedicated exclusively to business taxes. The Firm provides a comprehensive suite of tax services on a multi-jurisdictional basis, including tax recovery, consulting, advocacy, compliance, and technology services. Ryan is a five-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA). Ryan’s multi-disciplinary team of more than 2,100 professionals and associates serves over 14,000 clients in more than 45 countries, including many of the world’s most prominent Global 5000 companies. Learn more at ryan.com.
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