2022 OECD USCIB Tax Conference

 

 
 

until we see each other in person

at the Four Seasons in Washington, D.C.

June 27, 2022

8:30 a.m. – 6:00 p.m.
6:00 – 7:30 p.m. Cocktail Reception

June 28, 2022

8:00 a.m. – 1:00 p.m.

The event is sold out.

We’re back! Now in its 15th year, this annual conference provides a unique opportunity for the U.S. business community to interact with key representatives from the OECD Centre for Tax Policy and Administration (“CTPA”) as well as key members of the OECD’s Committee on Fiscal Affairs: including Pascal Saint–Amans, Director, CTPA, and Grace Perez–Navarro, Deputy Director, CTPA. Speakers will also include Fabrizia Lapecorella, the new Chair of the OECD’s Committee on Fiscal Affairs and Director General for International Taxation at the Italian Ministry of Finance. The focus of the conference will be on the Two Pillar Solution to the Tax Challenges of the Digitalization of the Economy but will also cover other key international tax issues.

What You Need To Know

DAY 1

8:00–9:00

Tax Committee “Open House”

Registrants are invited to join Rick Minor at their initiative for questions and suggestions regarding the USCIB,  BIAC and ICC tax committees.

8:30–9:30

Registration

9:30–10:00

Welcome and Opening Remarks

  • Fabrizia Lapecorella, Chair, OECD Committee on Fiscal Affairs; Director General   of Finance,  Ministry of Finance, Italy
  • Rick Minor, Vice President & International Tax Counsel, USCIB
  • Tim McDonald, Senior Vice President-Finance & Accounting, Global Taxes, The Procter & Gamble Company

10:00–11:00

Two Pillar Solution to Tax Challenges of Digitalization of the Economy

After years of discussions, in October 2021, more than 130 countries and jurisdictions of the OECD/G20 Inclusive Framework on BEPS agreed a landmark Statement and Detailed Implementation Plan on the two-pillar approach to addressing the tax challenges arising from the digitalization of the economy, which was subsequently endorsed by G20 Finance Ministers and Central Bank Governors at their October meeting. Pillar One is intended to ensure a fairer distribution of profits and taxing rights among countries with respect to the largest MNEs through an innovative formulaic approach. Pillar Two sets a floor on tax competition on corporate income tax through the introduction of a global minimum corporate tax that does not eliminate tax competition but does set multilaterally agreed limitations on it. This panel will provide the broad overview of the work and discuss next steps.

  • Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration
  • Itai Grinberg, Deputy Assistant Secretary for Multilateral Tax Office of Tax Policy, U.S. Treasury
  • Martin Kreienbaum, Director General, International Taxation, Federal Ministry of Finance, Germany
  • Tom Hutchinson, Vice President, Finance, Google
  • Alan McLean, Chair, BIAC Tax Committee and Executive Vice President, Taxation and Controller, Shell International Limited, United Kingdom
  • Lisa Wolski, Head of Government Affairs and Senior Executive Counsel, General Electric

11:00–11:20

Refreshment Break

11:20–12:30

Pillar One: Part I

Pillar One is intended to restore stability to the international tax system by bringing it into the 21st century. It re-allocates taxing rights over 25% of the residual profit of the largest and most profitable MNEs to market jurisdictions (Amount A). It does so through a formulaic approach applied to the MNE group’s profits.  This panel will discuss the overall design of Amount A and some of the key aspects of Amount A such as revenue sourcing, nexus and tax base.

  • Achim Pross, Head, International Cooperation and Tax Administration Division, OECD Centre for Tax Policy and Administration
  • Gaël Perraud, Co-Chair, OECD Task Force on the Digital Economy Director of International Taxation and European Affairs, Ministry of Economy and Finance, France
  • Itai Grinberg, Deputy Assistant Secretary for Multilateral Tax Office of Tax Policy, U.S. Treasury
  • Tracee Fultz, Global Transfer Pricing Leader, Ernst & Young LLP
  • Tim McDonald, Senior Vice President-Finance & Accounting, Global Taxes, The Procter & Gamble Company
  • Loren Ponds, Member and Co-Lead of the Tax Policy Practice, Miller & Chevalier

12:00–1:30

Luncheon and Keynote Address

Keynote Address delivered by Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration.

2:00–3:15

Pillar One: Part II

This panel will continue the discussion of Amount A focusing on the scope of the provision, including the exclusions for extractives, and regulated financial services. It will also consider the issues associated with the elimination of double taxation, the marketing and distribution safe harbor and withholding taxes. Tax certainty issues will be covered in Session IX.

  • Achim Pross, Head, International Cooperation and Tax Administration Division, OECD Centre for Tax Policy and Administration
  • Michael Plowgian, Co-Chair, OECD Task Force on the Digital Economy and Counsellor, Office of Tax Policy, US Treasury
  • Will Morris, Deputy Global Tax Policy Leader, PwC
  • Danielle Rolfes, Co-Partner in Charge, Washington National Tax-International Tax, KPMG
  • Daniel Smith, Director, International Tax Planning & Policy, Google
  • Mike Williams, Director Business and International Tax, HM Treasury, United Kingdom

3:15–3:35

Refreshment Break

3:35–5:00

Increased Global Mobility of Workers—What does it mean for tax policy?

Digitalization has led to significant changes in labor markets, with teleworking having expanded dramatically as a result of the pandemic and with new types of jobs that can be done anywhere increasing. Physical presence is a key determinant of corporate income tax nexus and taxing rights such as PE creation and company residence. Physical presence also plays an important role in transfer pricing (e.g., income allocation, profit attribution if PE is created). At the same time, tax incentives to attract so-called “digital nomads” are being introduced. The OECD issued some interim guidance at the onset of the pandemic but is it time to take a deeper look at these issues? This panel will discuss the tax treaty, transfer pricing and other implications of this trend for businesses, individuals and tax policy and tax administration.

  • Grace Perez-Navarro, Deputy Director, OECD Centre for Tax Policy and Administration
  • Liz Chien, Global Head of Tax and Chief Tax Counsel, Protocol Labs Inc.
  • John Harrington, Partner, Dentons US LLP
  • Liz Stevens, Member, Caplin & Drysdale
  • Bret Weaver, Partner, KPMG
  • Mike Williams, Director, Business and International Tax, HM Treasury, United Kingdom

5:00–6:00

Tax and Climate Change

Countries have committed to ambitious emissions reduction targets and a growing number have committed to net-zero greenhouse gas emissions by 2050 while others are already moving in that direction. However, and in spite of significant progress made to date, near-term policy actions on climate remain insufficient to meet the Paris Agreement objectives, and the diversity of policy approaches risks limiting their combined impact as well as elevating the likelihood of negative spillovers. To ensure the effectiveness of combined efforts and to avoid adverse interactions with trade and development agendas, the OECD has proposed establishing an inclusive forum for greater multilateral dialogue, informed, and facilitated by technical and objective analysis of carbon pricing and other climate mitigation measures, building on the OECD’s comparative data in Taxing Energy Use.  This panel will discuss the latest developments in this area.

  • Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration
  • Fabrizia Lapecorella, Chair, OECD Committee on Fiscal Affairs, and Director General of Finance, Ministry of Finance, Italy
  • Hannah Hawkins, Principal, KPMG Washington National Tax, KPMG
  • Alan McLean, Chair, BIAC Tax Committee and Executive Vice President, Taxation and Controller, Shell International Limited, United Kingdom

6:00–7:30

Reception

DAY 2

7:30–8:00

Tax Committee “Open House”

Registrants are invited to join Rick Minor at their initiative for questions and suggestions regarding the USCIB,  BIAC and ICC tax committees.

8:00–8:30

Continental Breakfast

8:30–10:40

Pillar Two: Global Minimum Tax

This session will focus on the second pillar, which sets out the Global Anti-Base Erosion rules (GloBE) and the Subject to Tax Rule (STTR.) The GloBE rules, which were published in December 2021 and complemented by Commentary released in March 2022, aim to address the continued risk of profit shifting to entities subject to no or very low taxation through the development of two inter-related rules: an income inclusion rule and an under-taxed payment rule. The panel will discuss the main elements of the GloBE rules, STTR as well as the plan for implementation.

  • John Peterson, Head of Unit, Aggressive Tax Planning, OECDCentre for Tax Policy and Administration
  • Rebecca Kysar, Counselor to the Assistant Secretary for Tax Policy, US Treasury
  • Isaac Wood, Attorney-Advisor, Office of Tax Policy, US Treasury
  • Martin Kreienbaum, Director General, International Taxation, Federal Ministry of Finance, Germany
  • Barbara Angus, Global Tax Policy Leader, Ernst & Young LLP
  • Ryan Bowen, Senior Manager | Washington National Tax Office, Deloitte
  • Harris Horowitz, Managing Director, Global Head of Tax Policy & Innovation, BlackRock, Inc.
  • Louise Weingrod, Vice President, Global Taxation, Johnson & Johnson

10:40–11:00

Refreshment Break

11:00–12:00

Tax Certainty: Dispute Prevention/Dispute Resolution | Session 1

Under the Pillars: Dispute Prevention and Resolution

Enhancing tax certainty is a key element of the Two Pillar Solution to the tax challenges arising from digitalization. The October Statement calls for MNES that are in-scope of Pillar One to benefit from dispute prevention and resolution mechanisms to avoid double taxation for Amount A, including all issues related to Amount A. Given the formulaic approach to allocating profits under Amount A, this will call for innovative, multilateral approaches to dispute prevention and resolution. Amount B, which calls for simplification and streamlining of the application of the arm’s length principle as it applies to in-country baseline marketing and distribution activities is also intended to enhance tax certainty by reducing disputes on some of the most common transfer pricing cases. The Inclusive Framework is also considering tax certainty in the context of Pillar Two, as Implementation framework consistency, coordination, simplicity, and safe harbors. This panel will discuss the challenges and opportunities in designing rules to prevent disputes and ensure timely resolution of disputes under each of the Pillars.

  • Achim Pross, Head, International Cooperation and Tax Administration Division, OECD Centre for Tax Policy and Administration
  • Michael Plowgian, Co-Chair, OECD Task Force on the Digital Economy and Counsellor, Office of Tax Policy, US Treasury
  • Gaël Perraud, Co-Chair, OECD Task Force on the Digital Economy Director of International Taxation and European Affairs, Ministry of Economy and Finance, France
  • Mary Bennett, Senior Counsel, Baker & McKenzie
  • Tom Roesser, GM, Tax Policy Counsel, Microsoft

12:00–1:00

Tax Certainty: Dispute Prevention/Dispute Resolution | Session 2

Beyond the Pillars: Dispute Prevention and Resolution

The OECD Forum on Tax Administration continues to explore ways to increase tax certainty for taxpayers and tax administrations by making certainty available earlier, by making certainty processes more efficient, and by providing opportunities for certainty to be provided on a coordinated or multilateral basis. This panel will discuss the latest developments in the ICAP program, as well as work on streamlining the APA process, the possibility of multilateral APAs and MAP, and the wider use of standardized benchmarking.

  • Grace Perez-Navarro, Deputy Director, OECD Centre for Tax Policy and Administration
  • John Hughes, Director of Field Operations, Northeastern Compliance Practice Area (Mid-Atlantic) (LB&I), IRS
  • Nate Carden, Partner, Skadden
  • Mark Martin, Principal, Washington National Tax, KPMG
  • Tim McDonald, Senior Vice President-Finance & Accounting, Global Taxes, The Procter & Gamble Company
  • Sonja Schiller, Head of Global Tax Controversy, Netflix

1:00–1:05

Closing Remarks

  • Rick Minor, Vice President & International Tax Counsel, USCIB
  • Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration
  • Grace Perez-Navarro – Deputy Director, Centre for Tax Policy and Administration, OECD
  • John Peterson – Head of Unit, Aggressive Tax Planning, OECD Centre for Tax Policy and Administration
  • Achim Pross – Head of International Cooperation and Tax Administration Division, Centre for Tax Policy and Administration, OECD
  • Pascal Saint-Amans – Director, Centre for Tax Policy and Administration, OECD
  • Rick Minor – Vice President & International Tax Counsel, USCIB
  • Itai Grinberg – Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury
  • John Hughes – Director of Field Operations, Northeastern Compliance Practice Area (Mid-Atlantic) (LB&I), IRS
  • Rebecca Kysar – Counselor to the Assistant Secretary for Tax Policy, U.S. Treasury
  • Michael Plowgian – Co-Chair, OECD Task Force on the Digital Economy and Counsellor, Office of Tax Policy, US Treasury
  • Isaac Wood – Attorney-Advisor, Office of Tax Policy, US Treasury
  • Martin Kreienbaum – Director General, International Taxation, Federal Ministry of Finance, Germany
  • Fabrizia Lapecorella – Director General of Finance of the Italian Ministry of Economy and Finance and Chair of OECD Committee on Fiscal Affairs
  • Gaël Perraud – Co–Chair, OECD Task Force on the Digital Economy; Director of International Taxation and European Affairs, Ministry of Economy and Finance, France
  • Mike Williams – Director, Business and International Tax, HM Treasury, United Kingdom
  • Barbara Angus – Global Tax Policy Leader, Ernst & Young LLP
  • Mary Bennett – Senior Counsel, Baker & McKenzie
  • Ryan Bowen – Senior Manager, Washington National Tax Office, Deloitte
  • Nate Carden – Partner, Skadden
  • Liz Chien – Global Head of Tax and Chief Tax Counsel, Protocol Labs Inc.
  • Tracee Fultz – Global Transfer Pricing Leader, Ernst & Young LLP
  • John Harrington – Partner, Dentons US LLP
  • Hannah Hawkins – Principal, KPMG Washington National Tax, KPMG
  • Harris Horowitz – Managing Director, Global Head of Tax Policy & Innovation, BlackRock, Inc.
  • Tom Hutchinson – Vice President, Finance, Google
  • Mark Martin – Principal, Washington National Tax, KPMG
  • Tim McDonald – Chairperson, USCIB Tax Committee and Senior Vice President, Finance & Accounting, Global Taxes, The Procter & Gamble Company
  • Alan McLean – Chairperson, Business at OECD Committee on Taxation and Fiscal Affairs and Executive Vice President, Tax and Controller, Shell International Limited
  • Will Morris – Deputy Global Tax Policy Leader, PwC
  • Loren Ponds – Member and Co-Lead of the Tax Policy Practice, Miller & Chevalier
  • Tom Roesser – GM, Tax Policy Counsel, Microsoft
  • Danielle Rolfes – Co-Partner in Charge, Washington National Tax-International Tax, KPMG
  • Sonja Schiller – Head of Global Tax Controversy, Netflix
  • Daniel Smith – Director, International Tax Planning & Policy, Google
  • Liz Stevens – Member, Caplin & Drysdale
  • Bret Weaver – Partner, KPMG
  • Louise Weingrod – Vice Chairperson, USCIB Tax Committee and Vice President, Global Taxation, Johnson & Johnson
  • Lisa Wolski – Head of Government Affairs and Senior Executive Counsel, General Electric

The registration rate is $1,495 for USCIB members and $1,795 for non–members.

Registrations are non-refundable. Cancellations are liable for the full conference fee. You may send a substitute in your place for no additional charge. Substitutions must be requested, in writing, no later than Friday, June 10.

Conference Materials

  • USB Flash Drives with Background Documents will be included in materials handed out to attendees. Electronic copies are available to registered participants upon request.

PowerPoint Presentations

  • Hard Copies of PowerPoint Presentations will not be distributed. Electronic copies will be sent via email to participants when they are finalized.

Conference Logistics

Location Details: The conference will be held at the Four Seasons Hotel located at 2800 Pennsylvania Avenue NW. The meeting portion of the conference will take place in the Corcoran Ballroom located on the Banquet level. The Luncheon on Monday, June 27 will take place in the Dumbarton Conservatory next door to the Corcoran Ballroom.  The Reception, also on Monday, June 27, will take place in the Seasons Restaurant on the Lower Lobby Level.

Wireless Internet:  Wireless internet is available for conference attendees in the meeting room.  Please ask a member of the conference staff for the wireless password. Complimentary internet is also available to conference participants in your hotel room.

Parking:  Discounted Valet Parking is available at the conference venue, The Four Seasons Hotel, for conference attendees. Please pick up a parking validation sticker at the registration table for each day of the conference.

Metro: The nearest metro station is the Foggy Bottom-GWU station.  Both Blue and Orange lines stop at the Foggy Bottom Metro.  The Hotel is approximately a four-block walk from the metro. (Map below)

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A limited number of rooms have been blocked at the reduced rate of $435/night plus 14.95% tax at the conference venue, The Four Seasons Hotel, Washington, D.C.

Unbooked rooms (if any) will be released for general sale on June 6, 2022, and the group rate will not be available after this date.

Please contact the hotel Reservations Team at 202-342-0444 or by e-mailing res.washingtondc@fourseasons.com and mention the United States Council for International Business (USCIB) room block using the following code: 062722OECD.

Rooms reserved without a processed registration will be cancelled in order to ensure space for confirmed participants.

USCIB’s Tax Committee is the most respected U.S. business association on international tax issues. USCIB is the only U.S. business association formally affiliated with the world’s three largest business organizations where we work with business leaders across the globe to extend our reach to influence policymakers in international markets that… click here to learn more.

For sponsorship opportunities, please contact Alison Hoiem (ahoiem@uscib.org). 

For sponsorship opportunities, please contact Alison Hoiem (ahoiem@uscib.org). 

For registration support, please contact Diana Mendez (dmendez@uscib.org). 

For anything else, please contact Katya Nicholas (knicholas@uscib.org). 

2022 Sponsors:

 

Caplin & Drysdale

Black Deloitte Logo

Presented by:

USCIB logo

OECD

In association with:

IFA Logo

ITPF

 

Staff Contact:   Katya Nicholas

Executive Assistant, Office of the President
Tel: 212.703.5049

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