Join us June 6 and 7 in Washington, D.C. for the 8th Annual Bloomberg Tax and Baker McKenzie Global Transfer Pricing Conference. The Global Transfer Pricing Conference series brings together top government and regulatory officials, policy makers, senior practitioners from large multinational corporations, and leading industry experts to provide insight and analysis on the high level trends impacting transfer pricing in the coming year.
Over the course of the two days you'll learn about the transfer pricing implications from the Tax Cuts and Jobs Act. We'll address how government officials plan to implement the new law, how companies are adjusting their transfer pricing strategies, and how the reduced corporate tax rate could impact other countries and WTO rules.
In addition to a deep-dive on the impact of U.S. tax reform, we'll also address the OECD's work on financial transactions, key developments in taxation of the digital economy and expert insights and analysis on key transfer pricing issues including BEPS, country-by country reporting, attribution of profits to PE's, APA's, the MLI and more.
8:30 AM Breakfast and Registration
9:00 AM Keynote Session: IRS Spotlight
9:30 AM Transfer Pricing Implications of U.S Tax Reform
The Tax Cuts and Jobs Act of 2017 has, in many cases, transformed how transfer pricing rules will be applied going forward. Some examples include how transfer pricing will be affected by the lower US corporate income tax rate, changes to secs. 482 and 367, the BEAT, GILTI and FDII. This panel will provide an overview of the main provisions in the TCJA that impact transfer pricing issues.
Moderator: Julie Joy, Editorial Consultant, Bloomberg Tax
10:45 AM Break
11:00 AM What are Companies Doing and Seeing?
With the ambiguities and inconsistencies in the TCJA, the steady stream of Treasury and IRS guidance implementing the TCJA and BEPS implementation by various tax authorities, how are companies faring? Our panel will share case studies illustrating how companies are shifting their transfer pricing strategies in response to these pressing developments.
Moderator: Erik Christenson, Partner, Baker McKenzie, San Francisco
12:00 PM Lunch
1:00 PM Keynote Interview
Moderator: Alexandra Minkovich, Of Counsel, Baker McKenzie, Washington DC
1:30 PM IRS APMA: Achievements but Challenges Ahead
As transfer pricing enforcement approaches and rules evolve around the world, how have alternative dispute resolution avenues such as APA and MAP been affected? In this session, we will take a deep dive into how certain changes are projected to impact APA and MAP cases and share practical insights for how companies and the IRS can maximize the benefits of the APA and MAP processes.
Moderator: Richard Slowinski, Partner, Baker McKenzie, Washington, DC
3:00 PM SALTY Transfer Pricing: How are State and Local Tax Authorities Enforcing Transfer Pricing and Coping with the Transfer Pricing Implications of the TCJA?
State and local tax authorities have been augmenting their resources to address perceived transfer pricing abuses at the SALT level and increasing enforcement measures. This panel will look closely at the most recent developments in state and local transfer pricing enforcement and also evaluate the critical issues facing such tax authorities in connection with the TCJA.
Moderator: Lindsay LaCava, Partner, Baker McKenzie, New York
4:15 PM Keynote Interview
Moderator: Allyson Versprille, Congressional Reporter, Bloomberg Tax
4:45 PM Closing Remarks
5:00 PM Networking Reception
8:30 AM Breakfast
9:00 AM Keynote Interview
Moderator: Erin Gladney, Partner, Baker McKenzie, New York
9:30 AM Tax Disputes and Transfer Pricing Litigation
Tax and transfer pricing disputes and litigation continue to increase. At the same time, the IRS announced in December 2017 that it "can't continue to do things as they are." What do recent decisions tell us about future strategies to disputes and litigation? How is the IRS approaching the challenges it faces? These and other issues will be addressed as the session discusses the most recent cases and their impact on the future of transfer pricing.
Moderator: Patricia Anne Rexford, Partner, Baker McKenzie, Chicago
10:45 AM Break
11:00 AM International Impact: The Global Implications of Tax Reform
What are the top international implications of the TCJA, including WTO rules? How might the TCJA affect tax issues associated with digitalization? What might other countries do now that the US has lowered its corporate tax rate, and what are the key transfer pricing implications?
Moderator: Mounia Benabdallah, Partner, Baker McKenzie, New York/Amsterdam
12:15 PM Lunch
1:00 PM Conference Concludes
Mike Barker is a member of the Executive Management Tax Team at Fluor Corporation. Fluor is the world's largest, publicly owned engineering, procurement, construction, maintenance, fabrication, and project management company. In addition to project offices, Fluor maintains a network of offices in more than 25 countries across six continents. His responsibilities include transfer pricing, international provision, and international tax compliance and planning.
Transfer pricing responsibilities include development and implementation of Fluor's transfer pricing policies on a global basis. Mike also leads a team of in-house personnel and outside professionals in Flour's Unilateral/Bilateral APAs and Competent Authority proceedings including the development of positions and negotiations with relevant government authorities on all transferring pricing disputes.
International provision and tax planning responsibilities focus on minimizing Fluor's effective tax rate and cash tax flows on a global basis.
Mounia Benabdallah is a partner in Baker McKenzie’s International Tax Practice Group. She joined Baker McKenzie in 2006 and has practiced in the Firm’s offices in Amsterdam, Chicago and New York. As an attorney at law she is admitted to the Netherlands Bar. Mounia is repeatedly recognized as leading advisor in ITR’s Women in Tax Leaders guide. Because of her strong US focus, Mounia is based in New York and member of the Global Reorganizations Practice Group. Mounia mainly advises US multinationals on the interplay between US international tax law, European tax law and Netherlands tax law in global restructuring projects, with a strong focus on global (OECD BEPS) and European tax policy developments.
Erik Christenson practices in the area of general tax planning. For over 16 years, he has provided tax advice to multinational corporations — both US and foreign-based — in business taxation matters. He has also worked on significant pro bono matters, including applications for tax exempt status for various charitable organizations. Erik frequently speaks at internal workshops and seminars, as well as external events sponsored by, among others, the Tax Executives Institute (TEI).
Matt is a tax attorney with the Connecticut Department of Revenue Services. At the Department, Matt is responsible for legal matters relating to the Corporation Business Tax, including the implementation of the recently enacted combined unitary reporting regime and market-based sourcing rules. Matt has also worked extensively on matters that involve transfer pricing issues, particularly in his role as project manager of the corporate tax resolution initiative.
Prior to joining the Department, Matt was a state and local tax consultant at Ernst & Young LLP.
Matt received a B.S. in management from Boston College and received a J.D. from the University of Connecticut School of Law.
Maria P. Eberle is a member of the Firm's Tax Group in New York. She advises multinational companies on a full range of state and local tax matters, including tax controversy and litigation. Before joining Baker McKenzie, Ms. Eberle was a partner at an international law firm, where she concentrated on state and local tax matters. In addition, she was previously a manager of multistate tax services at a Big Four accounting firm where she advised individual and corporate clients on a variety of state and local tax issues. Ms. Eberle has also served as an adjunct professor of law at Quinnipiac University School of Law, where she taught a course on state and local tax.
Arlene Fitzpatrick is a Principal in the National Tax Department of EY in Washington, DC, where she works on general international tax issues with a focus on inbound and tax treaty matters. Prior to re-joining EY in October 2014, Arlene served as an attorney-adviser with the Office of the International Tax Counsel at the U.S. Department of Treasury. There, Arlene helped formulate international tax policy, draft international tax guidance, and negotiate income tax treaties. She also served as a Treasury representative on several OECD working parties and was engaged in the OECD's base erosion and profit-shifting project. Arlene received her LLM from the University of Iowa College of Law, and her bachelor of laws from University College Galway in Ireland. She also graduated from the Law Society of Ireland and is a member of the Iowa Bar.
Nikole Flax is Deputy Commissioner in the IRS Large Business and International (LB&I) Division. In this role, she assists the Division Commissioner in leading a workforce of 5,000 employees and shares responsibility for overseeing tax administration activities for corporations, subchapter S corporations, and partnerships with assets greater than $10 million and for administering the tax laws that affect individuals with international activity. Prior to joining LB&I, Nikole served as Deputy Chief in the Office of Appeals. Previous IRS positions include Special Assistant to the Chief, Appeals, IRS Chief of Staff, Deputy Chief of Staff, and Assistant Deputy Commissioner for Services and Enforcement.
Before joining the IRS in 2008, Nikole served for seven years as Legislation Counsel on the staff of the Joint Committee on Taxation where she provided technical and policy advice to Members of Congress and congressional staff on tax issues. Nikole was formerly a tax associate with the law firm of Strasburger & Price, LLP, in Dallas, Texas and is also a Certified Public Accountant. She received an LL.M. in Taxation from Georgetown University Law Center, J.D. from Southern Methodist University School of Law and B.S. in Accounting, from Louisiana State University.
Erin Gladney is a partner in the New York office of Baker McKenzie and a member of the Tax Group. Erin was named on The Network Journal’s “40 under Forty” list in 2016.
Jesse Hereford currently leads Walmart’s state income/franchise tax controversy group from the company’s corporate headquarters in Bentonville, AR. He will be celebrating 12 years with Walmart in August 2018. During his career with Walmart he has worked in many areas related to state income/franchise taxes including compliance, apportionment, tax planning and policy, and accounting for state income taxes.
Jesse’s current role is to manage all state income/franchise tax audits for the world’s largest retailer. This involves all aspects of the audits from IDR management to negotiating on behalf of Walmart at all levels in various jurisdictions. He is also primarily responsible for the upkeep of Walmart’s state FIN48 reserve analysis.
Prior to joining Walmart in 2006 Jesse spent three years with KPMG in New Orleans where he specialized in Louisiana income/franchise tax matters. Jesse received his B.S. in Accounting from the University of New Orleans and is a licensed private pilot.
John Hughes is Director, Advance Pricing and Mutual Agreement program (APMA) in the IRS. He joined the IRS as a manager in APMA in September 2011. Prior to assuming his current role, John was Senior International Advisor to the Director, Treaty and Transfer Pricing Operations. Before joining the IRS, John worked at the Washington offices of Mayer Brown LLP.
Julie is a former director in the transfer pricing practice of Deloitte Tax LLP, most recently managing the Carolinas transfer pricing practice. She has extensive experience assisting clients with international and multistate projects involving transfer pricing planning, documentation, and audit defense. Julie has 25 years of public accounting experience, of which 18 were devoted exclusively to transfer pricing.
Julie received her BBA Accounting from the University of Wisconsin-Eau Claire and her MST Taxation from American University.
Lindsay M. LaCava is a partner of the Firm’s Tax Practice Group in New York and advises individual and business clients on a full range of state and local tax issues. She was named a “Rising Star” in Tax Law in 2015 by Law360, and was selected by Super Lawyers as a New York-Metro "Rising Star" for Tax in 2013-2015. Prior to joining Baker McKenzie, Ms. LaCava was a partner in the state and local tax group of an international law firm. In addition, she previously worked at a Big Four accounting firm, where her practice focused exclusively on state and local tax. Ms. LaCava speaks on a variety of state tax topics at events around the country and also frequently writes about state and local tax issues.
Jeffrey Langer is the Senior Manager – State & Local Income Tax for The Home Depot, Inc. in Atlanta, Georgia, since 2015. In this role, Jeff focuses on State Income Tax Controversy including all aspects of state audits. Jeff also has a significant role in the entire state and local income tax function including planning, compliance, and ASC 740 considerations.
Prior to The Home Depot, Jeff spent 15 years in a similar role with a large media/automotive company as well as a large financial institution. Jeff began his career with Arthur Andersen and Deloitte.
Jeff received his B.S. in Real Estate Finance from The University of Florida in Gainesville, Florida, followed by his JD from Emory University, School of Law & MBA from Emory University, Goizueta Business School in Atlanta, Georgia. He is an active member of the Georgia Bar Association.
Marc Levey is a partner in the New York office of Baker McKenzie. He has over 46 years of experience in international taxation and is nationally recognized in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney as one of the "World's Leading Tax Advisors," included in its "Best of the Best" global tax experts. Mr. Levey serves as the chair of the Firm's Luxury & Fashion Industry Group. He was the past chair of the Firm's Global Transfer Pricing Steering Committee.
John B. Magee focuses on tax controversy with a general emphasis on complex domestic and international issues and a particular emphasis on transfer pricing issues. His transfer pricing experience includes extensive involvement with the identification, valuation, and movement of intangible properties in a wide range of industries. His more than 30 years' experience includes all aspects of income tax planning, Internal Revenue Service administrative proceedings, and tax litigation. John has been rated in Chambers USA Band 1 - National Tax Controversy since the category was established.
Mark J. Mazur is the Robert C. Pozen director of the Urban-Brookings Tax Policy Center and a vice president at the Urban Institute. His research interests cover all aspects of tax policy. From 2012 until early 2017, he was the assistant secretary for tax policy at the US Department of the Treasury. Mazur served in the federal government for 27 years in various positions, including policy economist at the congressional Joint Committee on Taxation, senior economist at the President's Council of Economic Advisers; senior director at the National Economic Council; chief economist and senior policy adviser and director of policy at the US Department of Energy; acting administrator of the Energy Information Administration; director of research, analysis, and statistics at the Internal Revenue Service; and deputy assistant secretary for tax analysis in the Office of Tax Policy. Before entering public service, Mazur was an assistant professor in Heinz College at Carnegie-Mellon University. He has a bachelor's degree in financial administration from Michigan State University and a master's degree in economics and a PhD in business from Stanford University.
Donna McComber is a director of economics for Baker McKenzie Consulting LLC in Washington, DC. She is a seasoned transfer pricing advisor with deep technical insight into complex transfer pricing issues. Prior to rejoining Baker McKenzie, Ms. McComber was assistant director of the Advance Pricing and Mutual Agreement Program (APMA) under the US Internal Revenue Service's Large Business & International Division. She managed teams that were responsible for cases in the following countries: Argentina, Caribbean countries, China, Denmark, Eastern European countries, Germany, India, Ireland, Israel, Mexico, Portugal, Norway, Spain, Sweden, Switzerland, UK and Venezuela.
Prior to becoming assistant director, she was the deputy director (technical) and reviewed US positions and negotiated APA MAP cases with treaty partners including Australia, Canada, China, Denmark, Germany, Japan, Mexico, Korea, Switzerland, and the UK. Prior to the IRS, Ms. McComber was a senior economist with Baker McKenzie.
Before joining Ernst & Young, Michael McDonald was a financial economist in the Business and International Tax Division of Treasury's Office of Tax Analysis.
In that role, Michael was a delegate representing the United States at Working Party 6 (Taxation of Multinational Enterprises) of the OECD's Committee on Fiscal Affairs, as well as a U.S. delegate on a number of WP6 and WP1 (OECD Model Tax Treaty) subsidiary groups. He served as the Chair of WP6. He was Co-Chair of WP6 for the BEPS work on transfer pricing (Action Items 8-10). He was a member of the United Nations subcommittee that drafted the United Nations Practical Manual on Transfer Pricing for Developing Countries, and a delegate to the OECD's Tax and Development Task Force. He participated in a number of bilateral income tax treaty negotiations.
As a specialist in transfer pricing, he has worked on a number of significant transfer-pricing projects, including the final, temporary and proposed cost sharing regulations (2005, 2009, 2011), the services regulations (2003, 2006, 2009), and the 2007 Report to Congress on Earnings Stripping, Transfer Pricing and U.S. Income tax Treaties. He has written a number of papers and articles on transfer pricing and corporate taxation.
In 2017, Mike received Bloomberg Tax Transfer Pricing Report's Lifetime Achievement award. In making the award, Bloomberg stated "Mike has played an integral role in shaping the future of transfer pricing over much of the quarter century that we have covered its developments, and we are very pleased to recognize his contributions."
Prior to joining the Treasury Department, Michael was a transfer pricing economist in the National Tax Department at Ernst & Young (1996-2001). Prior to working at E&Y, Michael was on the Revenue Estimating Division at Treasury's Office of Tax Analysis (1988-1996).
Michael received a Ph.D. in economics from Boston College in 1988.
Currently the head of transfer pricing with Honda's North American headquarters in Southern California, Mr. Pais de Melo is responsible for transfer pricing planning, compliance, and implementation, including the management of Honda's multilateral APA. With over 12 years of experience in transfer pricing and extensive experience in APAs, he has worked on several APAs involving multiple jurisdictions, and covering a wide range of intercompany transactions, transfer pricing methods, and issues. Prior to joining Honda, Mr. Pais de Melo was a member of KPMG's Global Transfer Pricing Services practice in Chicago, where, in addition to APAs, he also managed several transfer pricing planning, documentation and policy development projects, audit defenses, cost sharing arrangements, intercompany loan and cash pool analyses, and intangible asset valuations. He has also spent nearly two years with KPMG in Madrid, Spain, leading transfer pricing projects involving the many jurisdictions in the European Union.
Mr. Pais de Melo has a master's degree in taxation from the University of Southern California, and a master's degree in business administration from Case Western Reserve University. He is also a certified public accountant.
Alexandra Minkovich is a Counsel in Baker McKenzie's North American Tax Practice. She has over a decade of experience handling a variety of tax, tax controversy and legislative issues. She also brings significant experience representing clients with respect to domestic tax issues, including advising financial institutions, and is well versed in administrative law. Immediately prior to joining the Firm, Ms. Minkovich served as Associate Tax Legislative Counsel with the U.S. Department of Treasury, Office of Tax Policy. In that role, Ms. Minkovich advised the Assistant Secretary (Tax Policy) and General Counsel regarding tax policy considerations in regulations and Internal Revenue Bulletin guidance, provided advice on tax legislative proposals, and provided litigation advice regarding the validity of Treasury and IRS guidance. She also provided technical comments on tax legislation to the Senate Committee on Finance and the House Ways & Means Committee, as well as to individual members' offices.
Mark A. Oates is listed in Euromoney's Guide to the World's Leading Transfer Pricing Advisers. He has litigated many high profile cases won by taxpayers in the last decade, and has actively consulted on other prominent cases. He has also handled various international tax litigation cases involving issues in tax treaty interpretation, Subpart F and foreign tax credit - and a host of domestic issues in mergers and acquisitions, leveraged buy-out, valuations, research credit, inventory and civil fraud. Mr. Oates is the immediate past chair of the Firm's North America Tax Litigation Practice, and has an active pro bono criminal practice.
Loren Ponds serves as a Tax Counsel for the majority staff of the Ways and Means Committee. Prior to joining the Committee Staff, Loren worked in Ernst & Young's National Tax Department in Washington, DC, where she advised multinationals on the international tax aspects of their business operations - particularly in the areas of transfer pricing, supply chain restructuring and resolution of international tax disputes via advance pricing agreements or mutual agreement procedures as outlined in double taxation treaties. Before joining EY, Loren also spent time as a Trainee at the Organization for Economic Cooperation and Development, where she focused on issues related to transfer pricing and tax treaties.??Loren has an AB in French Language and Literature from Davidson College, a JD, cum laude, from American University - Washington College of Law, and an LL.M with distinction from Georgetown University Law Center.
Patricia Anne Rexford is a tax controversy and litigation partner in the Firm's Chicago office. She has over 20 years of experience representing taxpayers at all stages of tax controversies, including audit, IRS administrative appeals, trial, and appellate court review, including the US Supreme Court. Ms. Rexford has been recognized repeatedly by Legal 500 for her appellate, Supreme Court, and transfer pricing experience. She served as a special intern with the Foreign Affairs Department of the Kanagawa Prefectural Government in Yokohama, Japan from 1989-1990.
Congressman Peter Roskam is the Congressional representative for Illinois' 6thdistrict covering Winfield, West Chicago, Saint Charles and Barrington. He is currently in his sixth term of service.
Congressman Roskam serves as the Ways & Means Health Subcommittee Chairman for the 115th Congress where he plays a leading role in the first major overhaul of the nation's tax code in over three decades.
He also sits on the Tax Policy Subcommittee and previously led the Oversight Subcommittee-a key watchdog post with jurisdiction into the spending and operations of tax-writing and healthcare programs within the federal government.
Congressman Roskam was at the center of the investigation into the IRS after it was revealed the agency was targeting Americans for their personal, religious, and political beliefs, authoring legislation to protect against these abuses that became law. He also championed efforts to overhaul the troubled agency's civil asset forfeiture program and probed the relationship between the rising costs of college and the tax code.
Promoting America's role in the world, Congressman Roskam is Chairman of the House Democracy Partnership, assisting legislatures in emerging democracies; he serves as a co-chair of the House Republican Israel Caucus, the largest Republican congressional organization dedicated to strengthening the U.S.-Israel relationship; and he serves on the Board of Directors for the National Endowment for Democracy. He previously served on the Select Committee investigating the terrorist attack in Benghazi, Libya.
Richard Slowinski is a partner in Baker McKenzie's Washington, DC office. Richard has more than 25 years of experience advising clients regarding tax matters, with a focus on transfer pricing. He has been selected as a Recommended Lawyer and Leading Lawyer by International Tax Review and is recognized by Euromoney's Expert Guide for Transfer Pricing.
Richard has served in various leadership positions in Baker McKenzie, including as Chair of the Washington Office Tax Practice, a member of the North American Transfer Pricing Steering Committee, and the Washington Office Hiring Partner. He worked for one year in the Tokyo Office of Baker McKenzie.
Gary D. Sprague a 25-year veteran of international law and managing partner in Baker McKenzie's San Francisco/Palo Alto office, focuses his practice on international corporate tax planning and advice, tax controversies and e-commerce law, and represents software, high technology, and e-commerce companies. Mr. Sprague is a recognized leader in his field by Bay Area Lawyer Magazine, Best Lawyers in America, Northern California Super Lawyers, and Who's Who Legal and Guide to The World's Leading Tax Advisers. He is also regularly included among the North America's top tax advisers, most recently by the International Tax Review World Tax2011, and is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.
Eric Torrey has been a transfer pricing practitioner for over 15 years, with significant involvement in transfer pricing consulting/restructuring, economic analysis and valuation, controversy support (audit and litigation defense), transfer pricing documentation, and negotiations with various tax authorities, principally in the context of Advance Price Agreements (APAs). Mr. Torrey joined the Mexico City office of Baker McKenzie in 2000 as part of the original team that built the Latin America transfer pricing practice. After four years with the Mexico City office working with clients throughout Latin America, the US and Canada, Mr. Torrey transferred to the Washington, DC office in 2005. Mr. Torrey is a regular speaker at transfer pricing seminars.
Allyson Versprille is a congressional reporter for Bloomberg Tax covering major tax developments on Capitol Hill, such as the passage of the 2017 tax act. She also covers several regulatory areas of federal taxation including corporate tax issues, estate and gift taxes, trusts, tax-exempt bonds, and executive compensation.
She wrote about President Donald Trump's transition into office, offering insight into how his agenda, cabinet choices, and executive orders would impact tax policy. She has appeared on Bloomberg Radio, and her work has appeared in Wealth Management Magazine and Accounting Today.
A University of Virginia graduate, she interned at Bloomberg LP in New York and worked at National Defense magazine in Arlington, Va., before joining Bloomberg Tax.
Kirsten Wielobob is the Deputy Commissioner for Services and Enforcement of the Internal Revenue Service. She provides direction to the four taxpayer-focused IRS operating divisions, including Wage and Investment; Large Business & International; Small Business/Self-Employed and Tax Exempt and Government Entities. She also oversees the IRS Criminal Investigation Division, Office of Professional Responsibility, Online Services, the Return Preparer office and IRS Whistleblower Office.
Ms. Wielobob began her IRS career in 1997 as Assistant to the Commissioner of the Internal Revenue Service and has held a number of senior positions. These include Counsel to the National Taxpayer Advocate, Wage & Investment Division Counsel, and Assistant Deputy Commissioner for Operations Support. Ms. Wielobob joined the Office of Appeals in 2009 as Director, Technical Services. She subsequently served as both the Deputy Chief and Chief of Appeals.
Prior to joining the IRS, Ms. Wielobob worked as a Tax Associate in the law firm of Burt, Staples & Maner, and later at the law firm of Baker & McKenzie. In these positions, she advised multinational companies on tax controversy matters and domestic and international tax planning issues.
Ms. Wielobob holds a B.A. in economics from Smith College in Northampton, Massachusetts and a J.D. from the George Washington University Law School in Washington, D.C. She is a member of both the Massachusetts Bar and District of Columbia Bar.
Ken Wood is an international tax attorney with more than 35 years of experience in the public and private sectors. Ken began his career with the Office of Chief Counsel (IRS) in 1981, during which time he was primarily involved in providing guidance regarding transfer pricing, foreign tax credits, and anti-deferral issues. From 1995 to 2011 Ken worked in the National Office international tax practice of Ernst & Young, providing international tax planning and controversy advice to large corporate clients. In 2011 he returned to the IRS in its Transfer Pricing Operations group, focusing on negotiation of bilateral APAs and double tax cases in Competent Authority. He also served as acting Director of Transfer Pricing Operations before his retirement in January of 2016. Ken returned to the Office of Chief Counsel in August of 2016, where he serves as the Deputy Associate Chief Counsel (International – Transfer Pricing and International Programs).
Alejandro Barran is a Director at the Mexican Tax Administration office, where he is in charge of the analysis and negotiations of Transfer Pricing APA’s and MAP’s for non-oil & gas taxpayers.
At Mexico’s tax administration, Alejandro has also being part of Mexico’s Delegation at the OECD’s WP6 and FTA MAP Forum.
He holds a degree in actuarial science from the National Autonomous University of Mexico, and started his career in the TP field about 10 years ago in the consulting services, working for several industries, such as telecommunications, manufacturing, financial services, pharma, etc.
Cynthia Zuk is the Director of Global Transfer Pricing for Willis Towers Watson. Cynthia is responsible for the development and implementation of the firm's transfer pricing policies and strategies. She manages the global transfer pricing documentation process, required disclosures and works with key stakeholders in the firm to ensure transfer pricing best practices are being utilized. In addition, she manages transfer pricing controversy and oversees due diligence in M&A transactions as related to transfer pricing matters.
The National Press Club
529 14th St NW
Washington, DC 20045
Baker McKenzie defined the global law firm in the 20th century, and we are redefining it to meet the challenges of the global economy in the 21st.
We bring to matters the instinctively global perspective and deep market knowledge and insights of more than 11,000 people in 77 offices across 47 countries worldwide. We have a distinctive global way of thinking, working and behaving - "fluency" - across borders, issues and practices.
We understand the challenges of the global economy because we have been at the forefront of its evolution. Since 1949, we have advised leading corporations on the issues of today's integrated world market. We have cultivated the culture, commercial pragmatism and technical and interpersonal skills required to deliver world-class service tailored to the preferences of world-class clients worldwide.
Ours is a passionately collaborative community of 60 nationalities. We have the deep roots and knowledge of the language and culture of business required to address the nuances of local markets worldwide. And our culture of friendship and broad scope of practice enable us to navigate complexity across issues, practices and borders with ease.
Our Tax Practice is one of the most highly rated and recommended tax advisers amongst law firms worldwide. With a Global Transfer Pricing Team consisting of experienced professionals - economists, lawyers, tax advisors and public accountants, we are uniquely placed to design, implement, document and defend multijurisdictional transfer pricing structures.
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 firstname.lastname@example.org.
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 email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)