You re Invited. Tax Executives Institute Second Annual Houston Global Tax Symposium. Wednesday, October 1, 2014

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1 You re Invited Tax Executives Institute Second Annual Houston Global Tax Symposium Wednesday, October 1, 2014 Hilton Americas Houston Downtown 1600 Lamar St Houston, TX 77010

2 Approved for 7.0 Texas general CLE credits. A uniform certificate for out of state CLE requests can be provided upon request. A uniform certificate for 8.5 CPE credit hours will be provided for participants to use for CPE credit applications. Following a great inaugural program, don t miss Houston s Second Annual TEI Global Tax Symposium being presented by Baker & McKenzie and McDermott Will & Emery. Joined by keynote speaker Doug Poms of the U.S. Treasury Office of International Tax Counsel in Washington, DC, this highly informative full-day program will cover a wide range of topics relevant to companies operating globally across various industries, and will include sessions by leading experts on international tax planning and controversy, transfer pricing, inversions, tax treaty updates, and BEPS, among many others. The Symposium is meant to provide practical advice about realworld challenges faced by tax practitioners; from those new to their roles to seasoned professionals who have spent years on the front lines.

3 8:00 am - 8:50 am Registration and Breakfast 8:50 am - 9:00 am Welcome and Introductions: Henry Orphys, KBR, TEI Houston Chapter President Susan Stone, Partner and Chair of Tax Group, Houston office of Baker & McKenzie John Woodruff, Partner, McDermott Will & Emery Houston office 9:00 am - 10:00 am U.S. Legislative Update on International Tax: The panel will provide an overview of recent developments regarding U.S. international tax legislative proposals, including tax reform and anti-base erosion proposals. Emily Whittenburg, Shell Joshua Odintz, Partner, Baker & McKenzie Washington DC office Philip Morrison, Counsel, McDermott Will & Emery David Noren, Partner and Head of International Tax Group, McDermott Will & Emery 10:00 am - 11:00 am Tax Treaty Updates and Planning Under Existing and Pending Treaties: This panel will focus on U.S. tax treaty developments, including the evolving limitation on benefits provisions and beneficial owner requirements. The panel will also discuss various planning techniques utilizing existing U.S. treaties. Susan Musch, TEI Houston Susan Stone, Partner and Chair of Tax Group, Houston office of Baker & McKenzie Caryn Smith, Partner, Baker & McKenzie Houston office Philip Morrison, Counsel, McDermott Will & Emery Caroline Ngo, Partner, McDermott Will & Emery 11:00 am - 11:15 am Break 11:15 am - 12:15 pm Transfer Pricing Hot Issues: This session will address recent global transfer pricing developments in key jurisdictions, developments on the advance pricing agreement front, and best practices for managing transfer pricing in the current global environment. Cliff Mangano, Diamond Offshore Drilling Melinda Phelan, Partner, Baker & McKenzie Houston office Salim Rahim, Partner, Baker & McKenzie Mark Martin, Partner and Head of Global Transfer Pricing Group, McDermott Will & Emery Houston office Tracy Gomes, Chief Economist, McDermott Will & Emery Dallas office 12:15 pm - 1:45 pm Luncheon and Keynote Speaker: The keynote speaker will give highlights on the OECD s BEPS report to the G-20 and the U.S. Treasury Department s perspectives on BEPS developments. Janet Rudnicki, SCI Keynote Speaker: Doug Poms, Senior Counsel, U.S. Treasury, Office of International Tax Counsel, Washington, DC

4 1:45 pm - 3:15 pm The OECD s BEPS Report to the G-20: The first formal deliverables of the BEPS project have been approved by the OECD and are to be released in a report to the G20 Finance Ministers this September that is expected to include provisions regarding country-bycountry reporting and transfer pricing documentation, hybrid mismatch arrangements, anti-abuse limitations on treaty benefits, transfer pricing of intangibles transactions, harmful tax practices, and other provisions. The project continues to be fueled by high-level political support of OECD and G20 governments, and there will be increased pressure in the coming year to reach consensus on a series of challenging issues. This is raising the stakes of the project for the business community as well, with an increased risk of unilateral actions, double taxation, and disputes. The panel will discuss these developments with a focus on their practical implications for U.S. taxpayers. Harry Franks, Baker Hughes Mary Bennett, Partner, Baker & McKenzie John Peterson, Partner, Baker & McKenzie Palo Alto office Cym Lowell, Partner, McDermott Will & Emery Dallas office James Riedy, Partner, McDermott Will & Emery 3:15 pm - 4:15 pm Inversions Through Business Combination Transactions: Inversions through business combination transaction are at an all-time high and for good reason. The tax benefits of an inversion are significant and the window for accomplishing same may be closing quickly. The participants on this panel will focus on the opportunities that exist to invert under current law, strategies being utilized to do so, benefits that can be achieved through same, and the future outlook of inversion transactions based upon the current political and legislative climate. Kimberly Johnston, CenterPoint Energy Jonathan Martin, Partner, Baker & McKenzie Houston office Kai Kramer, Senior Associate, Baker & McKenzie Houston office Caroline Ngo, Partner, McDermott Will & Emery Barry Quirke, Partner, McDermott Will & Emery Chicago office 4:15 pm - 4:30 pm Break 4:30 pm - 5:30 pm International Tax Controversy Issues: A discussion of transfer pricing and other international tax controversy issues presently working through the Federal courts. The panelists will focus on substantive legal issues, procedural tactics and strategic gambits from the point of view of taxpayers and the government. Todd Miller, Baker Hughes Robert Albaral, Partner, Baker & McKenzie Dallas office George Clarke, Partner, Baker & McKenzie Jean Pawlow, Partner and Head of Tax Controversy Group, McDermott Will & Emery Elizabeth Erickson, Partner, McDermott Will & Emery 5:30 pm - 5:40 pm Closing Remarks: Henry Orphys, KBR, TEI Houston Chapter President 5:40 pm - 6:30 pm Networking Reception

5 Registration and Parking Tax Executives Institute Houston Global Tax Symposium Wednesday, October 1, 2014 Registration & Breakfast: 8:00 am 9:00 am Plenary Panel Program & Luncheon: Networking Cocktail Reception: Hilton Americas Houston Downtown Ballroom of the Americas (2 nd Floor) 1600 Lamar St Houston, TX :00 am 5:30 pm 5:30 pm 6:30 pm To register and reserve your place please visit: TEI Members: US$150 Non-Members: US$225 Parking: Complimentary self-parking will be provided with event validation. Please enter the Hilton Americas parking garage on Polk Street (behind main entrance of hotel). Upon parking, please take the skywalk located on the second floor of the garage and hotel and proceed to the Ballroom of the Americas located on the same floor. To map the hotel please click here. For more information or if hotel accommodations are needed, please contact: Joshua Rosales Azeema Mohaideen

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