1 st Annual Transfer Pricing Symposium

Transcription

1 1 st Annual Transfer Pricing Symposium Following are 2013 Panelists, which are in process of being updated for Please check back. Moderators and Panelists Moderators John I. Forry, JD, is the Director of Tax Programs and Professor-in-Residence International and Externship Programs, University of San Diego School of Law, where he oversees the LLM in Taxation program and teaches graduate-level courses in international finance and taxation. John currently divides his academic efforts among five U.S. and European law and business schools, as well as counseling private clients on international activities. He has served on the Advisory Group to the U.S. Commissioner of Internal Revenue and on numerous bar-related committees and projects. He has authored or coauthored five books and over 40 articles on international taxation, finance and investment. Russ O Haver, PhD in Economics, is a clinical professor in the business school at Northeastern University. Prior to that, Russ started and led for over 15 years Ernst & Young s New York based Transfer Pricing practice. In that capacity, Russ built one of the largest global Transfer Pricing practices -- of over 100 professionals in the Northeast -- and worked in all phases of transfer pricing, though specializing in Intellectual Property strategies and controversy defense (including APAs, audits, appeals, and litigation). Most of Russ s client clustered in the High Tech, branded Consumer Products and Media and Entertainment industries. He is a frequent speaker and writer in the field. David Bowen, LLM in Litigation and Dispute Resolution, Principal, Grant Thornton LLP. David is Grant Thornton s national leader for the Transfer Pricing practice located in Washington, D.C. He is a leading International Transfer Pricing Expert and National Managing Principal for Grant Thornton s U.S. Transfer Pricing Practice, and Chair, Global Tax Advisory Committee, Grant Thornton International. He has 28 years of experience in wide variety of complex tax and commercial litigation matters, including 11 years with Baker & McKenzie and 4 years with the IRS. He is a Law Professor, Transfer Pricing, University of Florida Graduate Tax Program (LL.M) and Law Professor, George Washington University, LAW 6682 International Dispute Resolution (LL.M.). Kenneth Christman Jr., JD, LLM in Taxation, is an Executive Director in Ernst & Young s National Tax Transfer Pricing practice in Washington D.C. Ken advises large multinational clients on transfer pricing controversy, planning and structuring, with a particular emphasis on cross-border transfers of intellectual property and cost sharing arrangements. Prior to Joining Ernst & young, he was an attorney with the IRS in the transfer Pricing Branch of the International Division. While there, Ken was the author of numerous regulations, including Treas. Reg T,Taxation of Cost Sharing Arrangements, and of other types of published guidance. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 1

2 U.S.-Mexico Transfer Pricing Tax Policy & Enforcement Development Panelists John Hinding, JD, is the Deputy Associate Chief Counsel (Strategic International Projects) with the IRS in Washington, D.C. Previously, John served as Director of the IRS Advance Pricing Agreement Program and Deputy Director of the new Advance Pricing and Mutual Agreement Program. John also worked in Branch 6 of the IRS Office of Associate Chief Counsel International and two law firms in Washington D.C. John has his B.A. cum laude from the University of Notre Dame, his J.D. from the Duke University School of Law, and his LL.M. in Taxation from Georgetown University Law Center. Sergio Luis Pérez, Servicio de Administración Tributaria, Mexico, has been at Mexican SAT s Central Administration for Transfer Pricing Examinations for the last seven years. Besides being the head of a transfer pricing audit team, he also directs the APA/BAPA program and conducts Competent Authority negotiations on BAPA s and MAP s with other tax administrations. As a Mexican delegate of the OECD s Working Party 6, Mr. Perez was involved in the Business Restructuring Project and also in the Comparability and Profit Methods Project that concluded with the most recent modifications to the OECD s Transfer Pricing Guidelines. An active participant of the OECD s education program, Sergio has been invited to lecture to other tax administrations in Central, South America and Asia. Thomas Vidano, JD, is the Deputy Division Counsel (International) in the Office of Division Counsel, Large Business & International (LB&I), where he manages the international tax program for his division. Prior to his current position, Mr. Vidano worked as an attorney in Branch 6 of the Office of Associate Chief Counsel (International), where he was one of the primary drafters of the Temporary Section 482 Services Regulations (published on August 4, 2006). He attended Stanford University, where he received an A.B. degree, with distinction, in 1985; the University of California at Los Angeles School of Law, J.D. degree in 1991; and, the University of San Diego School of Law, L.L.M. Taxation, summa cum laude, in Legal Issues and Trends in Transfer Pricing Panelists Paul Dau, JD, is counsel in the law firm of McDermott Will & Emery LLP based in the Firm's Silicon Valley office. He focuses his practice on complex international transactions involving intangibles, and on the resolution of federal tax controversies, from pre-audit preparation through litigation. Paul has extensive experience with all aspects of cross-border use of intangibles, including overlaps and conflicts between financial statement and tax valuations and disclosures, as well as the interactions between tax and IP law. Paul s practice also includes representation of clients in IP litigation relating to patents. Dr. Dau taught at University of California San Diego for eleven years before going to law school. Mike Patton, JD, LLM, is a partner in DLA Piper's Tax practice, based in Los Angeles. He focuses his practice on international transfer pricing. Mr. Patton has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes as well as in planning major cross-border transactions. He was instrumental in obtaining the world s first Advance Pricing Agreement and he has assisted clients in negotiating more than 100 APAs. Mr. Patton has been named one of the Best of the Best US transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the Legal Media Group. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 2

3 Craig Sharon, JD, is a partner in the Washington, D.C. office of Bingham McCutchen LLP. Craig focuses on international tax issues, including transfer price planning and dispute resolution in both unilateral and bilateral settings. Craig served as the Director of the IRS Advance Pricing Agreement (APA) Program for nearly three years, from April 2008 until February 2011, when he joined Bingham. As APA director, Craig s responsibilities included setting overall Program policies, resolving disagreements between APA teams and taxpayers and their representatives, strengthening relations between the APA Program and the IRS Field, coordinating with the U.S. Competent Authority, and negotiating directly with foreign tax authorities on particularly complex bilateral APAs. Economic Effects and Their Impacts on Transfer Pricing Panelists Oscar Burakoff is an economist in DLA Piper s Tax practice, based in San Diego. He has extensive experience performing transfer pricing analyses related to intangible property valuation and planning, cost sharing, royalty rates, business restructuring, Advance Pricing Agreements, audit defense, and global documentation. Mr. Burakoff s transfer pricing experience includes analyzing numerous transactions, including tangible property transfers, intangible property transfers, cost sharing, intercompany loans, and various services transactions. Before joining DLA Piper, Mr. Burakoff was a vice president at Duff & Phelps. His experience includes valuing intangibles to determine buy-in payments for companies implementing cost sharing arrangements, or for other tax/transfer pricing purposes in various industry sectors. Mike A. Denning, PhD, is a Principal based in Ernst & Young LLP s Orange County office. He has a Ph.D. in Economics and has been a leader in Ernst & Young s West Coast Transfer Pricing and Economics Practice since 1994, specializing in transfer pricing economics and related issues involving market analysis and valuation of tangible and intangible properties. Mike has broad transfer pricing and other tax-related background and expertise. His experience in the area includes development of methods, analyses, models, and reports used for documentation and evaluation of transfer pricing positions for tax planning and policy purposes. Josh Walls joined Duff & Phelps in 2012 as a director of Valuation Advisory Services with nearly a decade of experience advising clients on inbound and outbound transfer pricing planning and compliance matters including global implementation, bilateral advance pricing agreements, intangible property valuation, global policy studies, and corporate services analyses. Josh assists a range of clients, from start-ups to Global 100 companies, in the apparel, footwear, automotive, business services, direct selling, entertainment, healthcare, consumer products, industrial, and technology industries. Before joining Duff & Phelps, Josh established the Los Angeles office of Ceteris. Josh was also a founding member and Manager in FTI s Economic Consulting practice. John Young has been a transfer pricing economist for over 20 years and has worked for the IRS s LMSB division, Arthur Andersen, Price Waterhouse, and Deloitte Touche. Working for both the private sector and the government prepared him for his current position in the IRS s Appeals division, where for the last six years he has participated on settlement teams for a variety of transfer pricing issues, including cost sharing. John is now on a four-month assignment as the acting manager of Appeals transfer pricing economists. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 3

4 Mexican Transfer Pricing Development Panelists Jorge Castellon manages Ernst & Young s transfer pricing group in México and Central America. He has over 15 years of experience as a transfer pricing consultant and significant expertise in the development and management of transfer pricing projects designed to meet the regulatory requirements of the United States, México and other Latin American countries. Jorge has advised multinational corporations on a broad array of transfer pricing issues including optimization of supply chain structures, planning and documentation, valuation of intangible assets, negotiation of advance pricing agreement, competent authority proceedings and audit management. Jorge has a Bachelor in Economics and Finance from DePaul University in Chicago, and a MBA from Kellstadt School of Business in Chicago. Sergio Luis Pérez, Servicio de Administración Tributaria, Mexico, has been at Mexican SAT s Central Administration for Transfer Pricing Examinations for the last seven years. Besides being the head of a transfer pricing audit team, he also directs the APA/BAPA program and conducts Competent Authority negotiations on BAPA s and MAP s with other tax administrations. As a Mexican delegate of the OECD s Working Party 6, Mr. Perez was involved in the Business Restructuring Project and also in the Comparability and Profit Methods Project that concluded with the most recent modifications to the OECD s Transfer Pricing Guidelines. An active participant of the OECD s education program, Sergio has been invited to lecture to other tax administrations in Central, South America and Asia. Guillermo Villaseñor-Tadeo is a Tax Planning and Litigation Partner at Sanchez Devanny. Before joining Sánchez Devanny, he practiced as an Associate and Partner of an international law firm for sixteen years, rendering his services in Mexico City. He has broad experience in tax matters, including tax planning, taxation of corporate restructuring transactions, mergers, acquisitions, and general tax advice, especially for business and multinational groups with operations in Mexico. His experience also extends to transfer pricing, including the legal analysis of the implementation of policies, generation of contemporary documentation and elaboration of economic studies, as well as representation in court, including constitutional protection ( amparo ) proceedings initiated as a consequence of the creation or amendment of tax laws, and in other tax controversies. Supply Chain/Transfer Pricing Developments Panelists Randy Free is a Tax Partner at Grant Thornton LLP based in our Irvine office and the West Region Lead Partner of International Tax Services. Randy has nearly 25 years of experience providing international tax services to Fortune 500 multi-national corporations, public and private companies as well as start-ups. He has particular expertise serving technology clients. Randy has advised his clients on European restructuring to facilitate tax efficient repatriation of cash and evaluated and implemented intellectual property migration strategies to significantly lower tax rates and cash tax costs. He has coordinated a due diligence team in Israel and the U.S. to manage income tax exposures and developed a tax efficient acquisition/integration plan. Randy regularly manages teams throughout Asia Pacific on U.S tax provisions, offshore tax structures and strategies to minimize U.S. taxes. Ken Martin, International Tax Planning Director, Terex Corporation. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 4

5 Simón Somohano is a tax partner and leader of the Transfer Pricing and Economic Consulting at Deloitte in Latin America and the Caribbean region. He currently is responsible for supervising the application of tax, economic and financial criteria in transfer pricing and valuation analysis. He has more than twenty years of experience in transfer pricing, financial analysis, valuation, business model optimization, and international trade and taxation. His clients include several Fortune 500 companies doing business in Mexico. He has been named to the 2012 edition of Euromoney/Legal Media s Guide to the World s Leading Transfer Pricing Advisers. Under his leadership, Deloitte s Transfer Pricing practice has been recognized with the Americas Tax Awards as 2012 Mexico Transfer Pricing. TP Academic Research and the Practitioner Panelists Susan Borkowski, PhD, is Professor of Accounting and joint faculty in the Integrated Science, Business and Technology Program, at La Salle University, Philadelphia PA. She has published extensively regarding the international tax implications of transfer pricing, as well as the effects of managerial transfer pricing decisions on a transnational corporation s audit status and risk exposure. With Professor Gaffney at Temple University, Professor Borkowski is currently researching the actual versus perceived risk mitigation benefits of several proactive strategies, including advance pricing agreements and mutual agreement procedures. They are also assessing enterprise resource management as a potential transfer pricing risk mitigation strategy. Nicole Johnson, PhD in Accounting, has been an Assistant Professor at the Haas School of Business at UC Berkeley for seven years, where she teaches undergraduate and graduate courses in managerial accounting and contract theory. Her main research interests are managerial performance measurement and incentive alignment between managers and firm owners. She has several published papers, including studies on transfer pricing, stock option incentives, and capital budgeting mechanisms. Professor Johnson received her B.S. in Accounting and Master s Degree in Accounting and Information Systems from Brigham Young University. She earned a Master s Degree in Statistics and a Ph.D. in Accounting from Stanford University Russ O Haver, PhD in Economics, is a clinical professor in the business school at Northeastern University. Prior to that, Russ started and led for over 15 years Ernst & Young s New York based Transfer Pricing practice. In that capacity, Russ built one of the largest global Transfer Pricing practices -- of over 100 professionals in the Northeast -- and worked in all phases of transfer pricing, though specializing in Intellectual Property strategies and controversy defense (including APAs, audits, appeals, and litigation). Most of Russ s client clustered in the High Tech, branded Consumer Products and Media and Entertainment industries. He is a frequent speaker and writer in the field. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 5

6 Industry/Corporate Discussion Panelists Mark Hoose, JD, LLM, is Tax Counsel at Phillips 66. He teaches and writes in the areas of federal taxation, corporate taxation, international taxation, and taxation of intellectual property. Formerly, Mark was the managing tax counsel to Intel Corporation in Silicon Valley, Calif., senior tax counsel to Occidental Petroleum in Los Angeles, an associate in the Washington D.C. office of Baker & McKenzie, senior manager in Deloitte s international tax practice in San Francisco, and an associate in the international tax practice of PriceWaterhouse Cooper LLP in Chicago. Dr. Hoose s publications include "U.S. Report" in Taxation of Intercompany Dividend Distributions Under Domestic Law, EU Law, and Tax Treaties International Bureau of Fiscal Documentation, Brian Lynn, JD, LLM in Taxation, is Senior Tax Counsel at Hewlett-Packard Company. Mr. Lynn manages HP s worldwide tax controversy matters and advance pricing agreements. Mr. Lynn also handles HP s competent authority cases with the IRS and foreign tax authorities. Prior to joining HP, Mr. Lynn was with the law firm of Caplin & Drysdale in Washington, DC. Mr. Lynn received his JD from Harvard Law School and his LLM in Taxation from the Georgetown University Law Center. Greg Rocco is a Transfer Pricing Supervisor for Ford Motor Company, managing the company s global transfer pricing compliance for component and documentation. He utilizes his extensive experience in the execution of strategic initiatives, which fuels his desire for creative problem solving. He has also innovated Ford s transfer pricing tools by partnering with Thomson Reuters to automate and accelerate the company s transfer pricing year-end operational adjustments. Gregg has a wealth of global experience in finance, accounting, manufacturing operations, and earned Certification as a Six Sigma Black Belt. Prior to his experience in Transfer Pricing, Gregg served in a variety of Finance positions including: cost analysis, profit analysis, and financial analysis. Gregg earned a Bachelor of Science degree in Corporate Finance from Wayne State University, and a Masters in Business Administration/Leadership degree from Madonna University. Kathrin Zoeller has recently joined Weatherford as Sr. Director Transfer Pricing. Kathrin was hired to establish a team of economists responsible for transfer pricing. She has responsibility for all matters related to transfer pricing structures, planning, audit defense, compliance, and implementation. Prior to joining Weatherford she established transfer pricing functions for News Corporation, Diageo North America, and Siemens North America. Her work has spanned several industries that have been characterized by IP intangibles and marketing intangibles. Kathrin has also worked in the Arthur Andersen transfer pricing group in New York, in corporate Strategic Planning at Siemens Corporation, and management consulting at the Munich Reinsurance group. Moderators and Panelists 1 st Annual Transfer Pricing Symposium Page 6