8:30 - 9:15 am Keynote Address
Tim Perry, Managing Director, Co-Head of Oil & Gas Americas, Head of the Houston office,Credit Suisse, Houston, TX
9:15 - 10:30 am Industry Consolidation and Restructuring of Debt and Equity
Moderator: Jason Bazar, Partner, Mayer Brown, New York, NY
Panelists: Deborah Byers, Houston Office Managing Partner, US Oil & Gas Leader, Ernst & Young LLP, Houston, TX;
Brian McCabe, Co-head, Americas Oil & Gas Group, Investment Banking Department, Credit Suisse, Houston, TX;
Marc Rowland, Founder and Senior Managing Director, IOG Capital, L.P., Dallas, TX;
Louis Teuscher, Vice President, Tax, Talisman Energy Inc., Houston, TX
Energy companies are seeing significant changes resulting from drops in crude oil prices, and in response, there has been consolidation of different segments of the energy industry to remain competitive. Energy companies are revaluating their debt and equity capital structures. Private equity has played an important role in consolidation and capital restructuring. This session will discuss the consolidation trend and some of the restructuring techniques that are being employed.
10:30 - 10:45 am Break for Refreshments
10:45 am - 12:00 pm Transfer Pricing and What to Do After BEPS
Moderator: Clifford Mangano, Director, Global Transfer Pricing, Diamond Offshore Drilling, Houston, TX
Panelists: Peter Barnes, International Tax Counsel, Caplin & Drysdale, Washington, D.C.;
Jason Osborn, Partner, Mayer Brown, Washington, D.C.;
John Wells, U.S. Leader, Transfer Pricing and Global Leader, Oil & Gas Industry, Deloitte, Dallas, TX;
Kathrin Zoeller, Senior Director Transfer Pricing, Weatherford International Ltd, Houston, TX
The OECD BEPS project focus on transfer pricing is forcing energy companies to re-evaluate their current transfer pricing policies and tax authorities’ expectations. Country-by-country reporting, the creation of value by assets, both tangible and intangible, people functions, and the potential of recharacterizing transactions is forcing companies to reassess their transfer pricing policies. With the BEPS project nearing its completion, this session will discuss transfer pricing best practices given the post-BEPS tax environment and provide insights to how energy companies are adapting to the changes.
12:00 -1:00 pm Luncheon Session
1:00 -1:30 pm Keynote Address
U.S. Congressman Kevin Brady, Senior Member of the House Ways & Means Committee and Vice Chairman of the Joint Economic Committee
1:30 - 2:30 pm The Importance of Well Drafted Intercompany Agreements in Tax Planning
Moderator: Shawn O'Brien, Partner, Mayer Brown, Houston, TX
Panelists: David Canale, Principal, Transfer Pricing Controversy, Ernst & Young LLP, Washington, D.C.;
Myrtle Jones, Senior Vice President, Tax, Halliburton, Houston, TX;
Bruce Jorlando, Director International Tax, Cameron International Corporation, Houston, TX;
Joe Wood, Manager, Global Transfer Pricing, Deloitte Tax LLP, Houston, TX
Intercompany agreements generally form the basis of a company’s economic, functional, legal, and tax positions. 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 drafting intercompany agreements using real examples of energy company agreements to demonstrate how to bolster a taxpayer’s tax positions. The audience will learn practical tips and a basic approach to drafting intercompany agreements that will be beneficial, defensible, and sufficiently flexible and enduring to the company.
2:30 - 3:45 pm The Future of European Holding, Financing, and Trading Companies, and the Status of Tax Rulings
Moderator: Astrid Pieron, Partner, Mayer Brown, Brussels, Belgium
Panelists: Olivier Remacle, Founding Partner ATOZ SA, Luxembourg;
Godfried Schutz, Client Service Executive/Tax partner, Netherlands ICE Desk, Deloitte, New York
European holding, financing, and trading company structures are a longstanding element of an energy company’s organizational structure. Tax rulings provide companies with tax and legal certainty related to their European company structures. But do tax rulings have a future in Europe? The fight against tax avoidance and the search for transparency impacts current holding company structures. In particular, multi-national companies should pay attention to the EU’s proposal for automatic exchange of information between EU Member States on their tax rulings, the new EU Action Plan on corporate taxation, and the integration of OECD BEPS actions at EU level. The Netherlands, Luxembourg and Switzerland have already renewed their ruling processes to hopefully accommodate the new and ever evolving framework. This session will give a Pan-European view of the future of tax rulings related to European company structures.
3:45 - 4:00 pm Break for Refreshments
4:00 - 5:15 pm CFO and VP Tax Roundtable (In conjunction with the TEI Houston Chapter)
Moderator: Emily Whittenburg, Senior Tax Adviser-Tax Policy & Government Relations, Shell Oil Company and President, Tax Executives Institute - Houston Chapter, Houston, TX
Panelists: Martin Dunagin, Vice President, Corporate Tax, Hess Corporation, Houston, TX;
James Harris, Executive Vice President and Chief Financial Officer, Forum Energy Technologies, Inc., Houston, TX;
Amy Jolley, Vice President, Tax, Noble Energy, Inc., Houston, TX;
Chuck McGregor, Vice President-Tax, Helix Energy Solutions Group, Inc., Houston, TX;
Darren Miles, Vice President, Finance-Tax, Frank’s International LLC, Houston, TX
We have seen a high level of volatility in the energy industry over the past year. 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 its 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.
5:15 - 7:00 pm Cocktail Reception at Hyatt Regency
Day 2, September 22, 2015
7:30 - 8:00 am Breakfast
8:00 - 8:45am Opening Keynote Address: What Do the Presidential Tax Plans Mean for the Energy Sector and the U.S. Economy?
Scott Hodge, President, Tax Foundation,Washington, D.C.
8:45 - 9:45 am What’s New in the MLP Space
Moderator: Edward C. Osterberg, Jr., Partner, Mayer Brown, Houston, TX
Panelists: Brian Conner, Managing Director, Jefferies LLC, Houston,TX;
Timothy Fenn, Partner, Latham & Watkins, Houston, TX;
Greg Matlock, US MLP Leader, Partner/Principal National Tax Department – Energy, Ernst & Young LLP, Houston, TX;
Penny Wolf, Vice President, Tax, Enterprise Products, Houston, TX;
Bernardo Ramirez, Partner, Chevez Ruiz Zamarripa, Mexico City, Mexico
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, and the rise of alternative structures such as the Yieldco. This session will also focus on the recently proposed regulations that define qualifying income eligible for the natural resources exception and what to expect when these regulations are finalized. Consideration will also be given to the possibility of replicating the US MLP in Mexico for investment in the newly-opened Mexican energy sector. The panelists will offer their views from the standpoints of the VP-Tax and legal, accounting and banking advisors.
9:45 - 10:00 am Break for Refreshments
10:00 - 11:15 am Trending IRS Tax Controversy Issues Facing the Energy Industry
Moderator: Shawn O'Brien, Partner, Mayer Brown, Houston, TX
Panelists: Steven Diamond, Principal, Ernst & Young LLP, Houston, TX;
Wade McKnight, Director, Deloitte Tax LLP, Houston, TX;
Victoria Sherlock, Managing Director, Tax Controversy Services, KPMG LLP, Houston, TX;
Elizabeth Tucker, Managing Director, PricewaterhouseCoopers LLP, Dallas, TX
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 give a perspective from each of the Big 4 accounting firms on which tax controversy issues are trending for energy companies and the best practices to prepare a defense.
11:15 am - 12:30 pm Financial Audits and Tax Departments
Moderator: Jonathan Hunt, Senior Associate, Mayer Brown, Chicago, IL
Panelists: Gerrad Heep, Audit Partner and Houston Energy Industry Leader, Grant Thornton LLP, Houston, TX;
Phil Wedemeyer, Director, Chairman of Audit Committee, Atwood Oceanics, Houston, TX
Michael Osina, Partner, Grant Thornton, LLP, Houston, TX;
David Winn, Partner, Audit Services, Grant Thornton LLP, Houston, TX
Tax departments are routinely required to interact with the financial auditors. The PCAOB’s increased focus on tax has caused financial auditors to scrutinize company’s 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.
12:30 - 1:30 pm Luncheon Session
1:30 - 2:00 pm Keynote Address
Porter Bennett, President & CEO, Ponderosa Advisors, Denver, CO, United States
2:00 - 3:00 pm Best Practices When Entering New Markets
Co-moderators: Gonçalo Falcão, Partner, Mayer Brown, Rio de Janeiro, Brazil;
Ivan Tauil, Partner, Mayer Brown, Rio de Janeiro, Brazil
Panelists: Jonathan Batarseh, Vice President, Tax, KBR, Inc., Houston, TX;
Patrick Berrigan, Partner, PricewaterhouseCoopers LLP, Houston, TX
Dominic Savarino, Vice President, Tax, McDermott International, Inc., Houston, TX
Some of the largest energy and infrastructure projects over the next decade will be located in emerging markets, such as countries in Africa, Asia and South America. Energy company finance and tax executives typically lead their company's efforts to organize operations within these emerging countries. Experience dealing with unexplored markets is key to successful long-term investment decisions. This session will discuss the best approach in organizing operations in emerging countries. The panelists will share their experience with tax compliance, Foreign Corrupt Practices Act, withholding tax, immigration, local content, foreign currency, etc.
3:00 - 3:15 pm Break for Refreshments
3:15 - 4:15 pm Mexico
Moderator: Clifford Mangano, Director of Global Transfer Pricing, Diamond Offshore Drilling, Houston, TX
Panelists: Fred Barrett, Tax Partner, PricewaterhouseCoopers LLP, Mexico City, Mexico;
Francisco Moguel Gloria, Partner, Chevez Ruiz Zamarripa, Mexico City, Mexico;
Moisés Orozco Garcia, (official title pending), Mexico;
Nico Tran, Senior Tax Counsel, ConocoPhillips, Houston, TX
The recent Mexico Energy Reform strongly impacts the operating and tax model for energy companies looking to work in Mexico. The distinguished panel of government, industry and advisory organizations will address how the changes will affect the company’s commercial operations and tax policies. This session will provide practitioners with an update on the reform, including the latest informational rules and guidelines for the proposed production sharing and related contracts. Speakers will also share their views on the tax authority’s criteria for E&P contracts, thin capitalization considerations, rotator individual taxation rules, value-added tax refunds issues, electronic record-keeping matters, transfer pricing considerations and other relevant tax related issues. The panel will identify key tax issues for bidding on E&P contracts.
4:15 - 5:15 pm Brazil
Moderator: Ivan Tauil, Partner, Mayer Brown, Rio de Janeiro, Brazil
Panelists: Chuck McGregor, Vice President, Tax, Helix Energy Solutions Group Inc., Houston, TX;
Alfredo Neto, Tax Partner, Ernst & Young, Brazil;
Eduardo Telles, Partner, Mayer Brown, Rio de Janeiro, Brazil;
Chris Thompson, Director, International Tax, Cameron International, Houston, TX
Brazil has a complex, multi-level tax system which is challenging to even the most sophisticated energy company tax department. Specially 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 best court decisions and best tax practices relied on by oil and gas companies as they navigate Brazil’s complex tax regime.
5:15 pm Closing Remarks
Bonus Session: Live Webinar on State Tax Issues in the Energy Industry
(In conjunction with TEI Houston Chapter)
October 1, 2015
12:00 – 1:30 pm Live Webinar - Excise Taxes – Federal and State Excise Taxes Affecting the Energy Industry
Co-moderators: Shawn O'Brien, Partner, Mayer Brown, Houston, TX;
Jeffrey Reed, Associate, Mayer Brown, New York, NY
Panelists: Oscar Garza, Partner, Oscar L. Garza & Associates, P.C., Houston, TX;
Kelly Mathews, President, Kelly S Mathews LLC, Houston, TX
Richard Little, Senior Manager, Deloitte Tax LLP, Houston, TX
Excise Taxes on petroleum products have been in existence for years. Historically, Excise Taxes applied to traditional petroleum products, such as gasoline, diesel and jet fuel. However, changes in the petroleum industry in recent years have increased the reach of Excise Taxes. With the expansion of commercially available products, such as biodiesel and other renewable fuels, and new source/distribution networks due to the shale play, the number of companies impacted by Excise Taxes has increased sharply. Join us for this free webinar to learn more.
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