INTERNATIONAL TAX CONTROVERSY SUMMIT

REGISTRATION AND NETWORKING BREAKFAST

OPENING ADDRESS: OECD perspective on MAP, APAs and tax certainty

• Recent developments and the effects on MNEs
• Trends and future direction

Speaker

Sandra Knaepen, co-head of the tax certainty unit, OECD

PANEL NO 2: Tax authorities’ approach to international controversies - latest updates from Brazil and Canada

• How common tax controversies have been resolved with tax authorities in different countries
• What are the various countries' tax regulators who are auditing MNEs looking for?
• MAPs and APAs

Speakers

Spencer Stowe, team leader, Internal Revenue Service

Rodolfo Araújo, head of tax, ifood

Wesley Rocha, counsellor, CARF - Board of Tax Appeals

Katharine Ticknovich, VP taxation, Martinrea International

Workshop Session No 1:

This session will be split into two stream - with one workshop looking at how companies can prepare themselves practically, and - the other, tackling the strategic use of data exchange between tax authorities.

Workshop A: Effective audit management and prevention - how can companies prepare themselves?

• IRS insight - what to expect in terms of audits issued; IRS Campaign issues
• Audits related to TCJA
• Escalating controversies
• Going through mediation

Speakers

Robin Hart, principal - transfer pricing practice, Charles River Associates (workshop lead)

Brad Pees, lead tax controversy, Nestle

Alecia Wu, director global tax, Velodyne LiDAR

Workshop B: Latest OTA appeals process for the state of California

Speaker

Kristen Kane, chief counsel, OTA

Workshop Session No 2:

This session will be split into two streams - with one workshop looking at the practical skills needed for dealing with tax controversy, and - the other, tackling the strategic view required.

Workshop C: Practical view: Development of negotiation skills - managing the controversy process

• Dialogue and settlements between tax payers and tax authorities
• How to pro-actively gather information from the business and how to deal with future controversies
• How to prepare documentation effectively in light of new digital era rules designed
• IDR process - establishing lines of communication with exam team
• Successful tips for working with outside service providers

Speakers

Kim Boylan, partner, White & Case (workshop lead)

Brad Pees, lead tax controversy, Nestle

Tina McAlister, global tax planning & controversy, Twitter

Alecia Wu, director global tax, Velodyne LiDAR

Workshop D: Strategic view: Responsible tax - risk, governance and transparency

• Can internal audits drive change within a business?
• Corporate reputation management
• Tips on how to communicate your tax strategy to stake holders and customers

Speakers

Ewan Livingston, cause strategist, The B Team (workshop lead)

Leah Seligmann, director, The B Team

Jacqueline Matoza, director - international tax, Gilead Sciences

15.25

CASE STUDY: Alternative dispute resolution in a post BEPS world

This session will delve into how a large West Coast based corporation has dealt in practice with tax controversy post BEPS, such as double tax treaties.

16.40

CLOSING REMARKS AND COCKTAIL RECEPTION