ITR INTERNATIONAL TAX CONTROVERSY 2020

Robin Hart is a Principal within the Transfer Pricing Practice. Robin is a highly regarded transfer pricing and tax economist with 17 years of experience serving clients in the life sciences, technology, and consumer products sectors. He has assisted taxpayers with their strategic objectives relating to the transfers and licensing of intangible property, alignment of supply chains, the establishment of high-value and shared service centers, and intercompany financing. Focused primarily on innovative Bay Area companies, Robin has executed on cross-border and domestic transactions involving cost-sharing and IP planning, post-acquisition integration, global BEPS alignment, the launch of new digital business models, and business restructurings. Projects have included feasibility and planning, U.S. and OECD Action 13 documentation, APA submissions, ASC740-10, and audit defense. His recent experience includes assessing IP strategies in light of U.S. tax reform and BEPS for high growth medical device, biotechnology and fintech companies. Prior to joining CRA, Robin was a Managing Director with Deloitte Tax in San Francisco.

Brad Pees is currently the lead tax controversy for Nestle USA, where he is the primary person responsible for all IRS and state audit matters for all Nestle companies in the US. This includes coordination, direction and management of federal tax audits, state audits from audit ready files through examination and completion of audits. Prior to Nestle, Brad was the director federal tax audit for Tyco International from 2005-2018, including litigation, appeals and current exam. Brad was a team coordinator LMSB at Internal Revenue Service from 1986-2005, managing a team on-site for some of the largest federal tax examinations in the state of Ohio.

Melissa Hall oversees global tax planning and compliance for Assurant, including tax risk management and tax department strategy. She formerly served as VP of taxation and financial ratings, managing financial strength and debt ratings for the Assurant companies. She began with KPMG where she worked in both New York and London.

Ms. Hall graduated with distinction from George Washington University and earned her Masters in Taxation from Fordham University. She serves on the Board of The Tax Council and on the Advisory Board for the Tax Council Policy Institute’s Annual Symposium. Ms. Hall has been named to Treasury & Risk’s list of “Women in Finance,” and was named a Woman of Excellence and Achievement Honoree by the UWNYC. She is the Chair of the Manhattan Chapter of Women in Tax.

Ms. Hall lives in New York City with her husband and their four children.

Sandra Knaepen has more than 20 years of experience with international taxation and dispute resolution. She was until September 2016 head of the International Relations Division within the Belgian Ministry of Finance where dealing amongst other things with treaty interpretation, exchange of information, MAP and APA. She was for many years the Belgian delegate to the EU Joint Transfer Pricing Forum and she attended Working Party 6 meetings and the meetings of the FTA MAP Forum at the OECD. In September 2016, she joined the OECD as head of the MAP Unit, i.a. responsible for the coordination of the BEPS Action 14 MAP peer reviews. She recently became co-head of the newly created Tax Certainty Unit.

Head of White & Case's Global Tax Practice, Kim Marie Boylan is a highly respected tax attorney. She has a long track record of creating innovative, practical approaches for the successful resolution of tax disputes. A renowned tax litigator, she also effectively utilizes the IRS's administrative appeals procedures, fast track, mediation and other alternative dispute resolution processes. Kim represents a broad spectrum of companies in connection with sophisticated domestic and international tax issues. Her practice focuses mainly on civil tax matters, but throughout her career she has also successfully represented clients on criminal tax matters. As a recognized authority on privilege, Kim often advises companies in connection with the complicated issues that arise in this area, and numerous clients seek her knowledge and insight in judicial proceedings in the United States Tax Court, United States Court of Federal Claims, and in various district and appellate courts.

Her practice encompasses transfer pricing, as well as the Advance Pricing Agreement process, an area of practice that is greatly enhanced by her credentials as a Certified Public Accountant. Kim has also testified on clients' behalf before the United States Treasury Department, Internal Revenue Service and the Financial Accounting Standards Board.

Kim is a frequent speaker on tax controversy, transfer pricing and accounting policy issues, and writes extensively on these issues. She is a member of the J. Edgar Murdock Inn of Court at the United States Tax Court, the American Bar Association and the District of Columbia Bar Association.

Brian Gleicher heads White & Case's transfer pricing practice and focuses on international and domestic tax disputes. He routinely represents multinational companies in transfer pricing matters, including advance pricing agreements, with the Internal Revenue Service and foreign tax authorities. He also advises taxpayers on proceedings before the US and foreign competent authorities on a broad range of issues, including double taxation, residency and permanent establishment questions. Additionally, Mr. Gleicher represents corporate and individual taxpayers in domestic tax examinations and settlement negotiations with the Internal Revenue Service at the examination and appeals levels.

Brian received his BS, with high honors, in 1992 from the University of Florida, Fisher School of Accounting and his JD cum laude in 1995 from the Georgetown University Law Center, where he served as a lead articles editor of the Tax Lawyer.

He is a member of the District of Columbia Bar and is admitted to practice before the US Tax Court. He is a member of the Transfer Pricing Committee of the American Bar Association Section of Taxation and has served as the chair of the Federal Bar Association Section of Taxation.

Steven Shee is the Vice President of Global Tax for Applied Materials, the global leader in materials engineering solutions for the semiconductor, flat panel display and solar photovoltaic (PV) industries. Steven joined Applied Materials in 2019 and is responsible for global tax stewardship for the Company. Prior to Applied Materials, Steven was the Vice President of Global Tax and Government Relations for SanDisk, providing stewardship for the Company’s tax and public policy matters around the world. Steven has over 20 years of global experience, and prior to SanDisk held tax leadership positions at Deloitte, ARCO, CB Richard Ellis and Hewlett Packard. Steven previously held assignments in Beijing, Hong Kong and Singapore. Steven also teaches Ethics and Statistics at local colleges.

Steven has a Bachelor's degree in Business Administration from the California State University at Los Angeles and a MBA in International Finance at the University of Southern California.

Steven is a member of the American Institute of Certified Public Accountants. He served as Board Alternate for the Semi-Conductor Association (SIA), Board Member of United States Information Technology Organization (USITO), Asia Chapter President of the Tax Executive Institute and Executive Chairman of the Hewlett-Packard Asia Pacific Employee Network (HAPEN).