Rick Minor Archives

Director International Tax Policy and Banking

Published on March 15, 2024

Position: Director International Tax Policy and Banking
Organization: United States Council for International Business
Reports to: Vice President & International Tax Counsel
Location: Washington D.C.

THE OPPORTUNITY – About USCIB

Founded in 1945, USCIB promotes open markets, competitiveness and innovation, sustainable development, and corporate responsibility, supported by international engagement and regulatory coherence.  Its focus is on international policy in the multilateral system, and its members include U.S.-based global companies and professional services firms from every sector, with operations in every region of the world. As the sole American representative of the International Chamber of Commerce, the International Organization of Employers and the Business and Industry Advisory Committee to the OECD, USCIB provides business views to the Administration and to policy makers and regulatory authorities worldwide and works to facilitate international trade and investment. In addition, USCIB serves as the National Guaranteeing Association for ATA Carnets, which allows temporary, tax and duty-free imports overseas for trade shows, commercial samples and professional equipment. More at www.uscib.org

POSITION SUMMARY

The Director International Tax Policy and Banking will support the Vice President & International Tax Counsel on a variety of programs and projects involving the development and dissemination of USCIB tax policy positions, papers and meeting preparation and materials. The Director will support USCIB member engagement and development for the organization’s Tax committee and have the possibility to lead in defined international tax policy areas with the potential to expand responsibilities in the course of the role.  The Director will also oversee and manage the Banking Committee.

PRIMARY RESPONSIBILITIES

  • Lead policy expert and work product drafter on U.S. Congress, U.N., single country and developing countries portfolios. Support VP on OECD and U.S. government, and European (member state and European commission) tax policy portfolios.
  • Prepare and participate in internal USCIB planning meetings, webinars, Tax Committee meetings and events, and the annual OECD international tax conference.
  • Work with the Tax Committee leadership team and member companies to understand their tax policy needs and develop policy positions that support their interests.
  • Monitor and analyze tax policies and legislation in respective portfolios.
  • Conduct research and analysis to identify emerging tax policy issues and opportunities for advocacy.
  • Oversee and manage USCIB Banking Committee, working with committee leadership to engage with ICC Banking Commission and related partner organizations.
  • Support Banking Committee member priorities, including those regarding digitization of trade finance and promoting standardization of international banking and commercial practices.
  • Represent USCIB before government officials, advocacy groups, and other stakeholders to promote our members’ interests and the growth of international business.
  • Develop and maintain relationships with key stakeholders, including government officials, business leaders, and advocacy groups.
  • Assist the membership department in new member and retention efforts by identifying potential new members, setting goals for annual recruitment, and nurturing relationships with existing members.

QUALIFICATIONS/EXPERIENCE

  • Advanced degree (e.g., JD) or equivalent combination of education and experience.
  • 10 years of experience in international tax and/or international tax policy in the public and/or private sector, U.S. Congress, U.S. government, Big Four accounting or law firm or other advocacy organization. Demonstrated knowledge of global frameworks and institutions that influence the development of international tax policy. Some banking regulatory experience required.
  • Demonstrated ability to work independently, manage multiple projects against tight deadlines as well as work collaboratively in team settings.
  • Superior time-management skills with respect to setting priorities and managing multiple workflows against tight deadlines.
  • Strong written communication and advocacy skills.
  • International work experience and foreign language skills preferred.
  • Some international travel required.

SALARY AND BENEFITS

Salary and title are commensurate with qualifications and experience. The salary range for this role is between $150,000 and $175,000 per year. USCIB offers a highly competitive compensation package that includes medical, dental and vision insurance, a 401(k)-retirement company matching program, generous paid time off, and the ability to participate in pre-tax transportation/commuter benefit and flexible spending account programs.

USCIB currently requires in-office work Tuesday – Thursday, with WFH option on Mondays and Fridays.

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Note: Only shortlisted candidates will be contacted. Thank you for your understanding.

Taxation

Published on June 14, 2023

Magnifying Your Voice with USCIB:

  • 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 are important to American business.

Trends and Challenges Facing U.S. Business:

  • Multiple sets of inconsistent rules that drive up costs and result in double taxation
  • The mounting political pressure to move towards changing the taxation of the digitalized economy
  • Efforts to unfairly increase the tax burden on companies

USCIB’s Response:

  • Build consensus with like-minded industry peers and participate in off-the-record briefings with policymakers both home and abroad
  • Engage with the OECD on the development of international taxation principles
  • Proactively shape the development of the OECD’s guidance on the taxation of the digitalized economy by demonstrating to policymakers that unilateral action can result in double taxation, decreased trade, and reduced global growth
  • Actively monitor and contribute to the work of the UN Committee of Tax Experts to ensure its alignment with the work of the OECD Tax Committee and inform policymakers of their actions’ impact on investment
  • Support enactment of foreign tax simplification provisions in the IRC that would significantly reduce the burden of complexity for U.S. companies and enhance their international competitiveness
  • Host an annual conference in Washington, DC that 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”).

USCIB on LinkedIn

Recent Accomplishments:

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Chair

John A. Stowell
Head of Global Tax and International Financial Reporting
The Walt Disney Company

Vice Chairs

Jocelyn Krabbenschmidt
International Tax Director
Apple Inc.

Carolina Perez-Lopez
VP Global Tax Planning and Tax Counsel
Johnson & Johnson

Tom Roesser
Senior Director, Tax Affairs
Microsoft Corporation

Vice Chairs

Erik Rosenfeld
VP Taxes, North America
Procter & Gamble

Daniel Smith
Director, International Tax Planning & Policy
Google Inc.

Lennaert ten Cate
SVP Tax
PepsiCo Inc.

Wendy Unglaub
VP, Chief Tax Officer, and Principal Tax Counsel
General Mills

Vice Chairs

Jason Weinstein
Vice President, Tax, North America
Amazon

Chad J. Withers
Chief Tax Officer
Caterpillar Inc.

USCIB Leadership

Rick Minor
Vice President and International Tax Counsel
202-682-7376 or rminor@uscib.org

Subcommittees

Transfer Pricing Subcommittee

VAT Subcommittee

Working Groups

EU Tax Working Group

USCIB Announces Appointment of Five New Tax Leadership Team Members (Vice-Chairs, USCIB Tax Committee)  

Published on March 23, 2023

Rick Minor, USCIB VP and International Tax Counsel, is happy to announce five new appointments to the Tax Committee Leadership Team (Vice-Chairs). Leadership team members serve a two-year term with an option to renew for a second, consecutive term.

“These appointments resulted from several retirements from the Tax Committee Leadership Team at the end of last year and the creation of a Big Four International Tax Policy Board as part of our Tax Committee governing structure,” said Minor. “Being part of the Tax Committee Leadership Team is a significant commitment by the team members who are all senior tax executives at leading member companies. I look forward to enjoying their support and counsel along with that of our legacy members.”

The new Vice-Chairs:

Lennaert ten Cate, SVP Tax, PepsiCo Inc. Lennaert has over 28 years of tax experience of which 25 with PepsiCo Inc. Prior to serving as SVP Tax, Lennaert served as SVP, International Tax, leading the corporate tax agenda for PepsiCo’s international operations and partnered with the business and other corporate functions on various business initiatives and M&A transactions. Lennaert has worked in the Netherlands, the United Kingdom, Hong Kong and in the US, where he is currently based. Prior to joining PepsiCo in 1996, Lennaert spent three years at Ernst & Young Tax Advisory in Amsterdam, the Netherlands. Lennaert holds a Master of Law degree from Leiden University, the Netherlands.

Carolina Perez-Lopez, VP Global Tax Planning and Tax Counsel, Johnson & Johnson. In her role, Carolina is responsible for driving the tax strategy and execution for acquisitions, divestitures, licensing deals, and restructurings for the enterprise, as well as the tax planning for the Pharm and MedTech businesses worldwide.  Prior to joining Johnson & Johnson, Carolina was Vice President, Transfer Pricing and Senior Tax Counsel at Pfizer. Before that, Carolina worked as a counsel at Clifford Chance LLP, spending time both in New York and London. Carolina holds a JD and Master of Laws (LLM) in Spanish Taxation from the Universidad de Navarra, Spain, and an LLM in International Taxation from New York University, School of Law.

Erik Rosenfeld, VP Taxes, North America, Procter & Gamble. Erik leads the North America Tax Operations Team of The Procter & Gamble Company.  In this role, Erik’s responsibilities cover US GAAP external reporting on tax matters, North America direct and indirect tax compliance, M&A and cross-border tax issues, global tax technology and various global tax policy matters.  From 2018 – 2021, Erik led P&G’s European Tax organization from P&G’s international headquarter location in Geneva, Switzerland.  Prior to joining P&G, Erik spent 18 years in public accounting, including six years as an international tax partner with PwC.

Wendy Unglaub, VP, Chief Tax Officer, and Principal Tax Counsel, General Mills. Wendy leads the global tax function at General Mills, with responsibility for managing all aspects of the company’s tax profile from compliance to litigation to identifying solutions to business needs. Prior to joining General Mills, Wendy served in a variety of leadership positions at Microsoft Corporation, Ecolab and Cargill where she was responsible for a wide range of U.S. and international tax matters related to legislative policy, joint ventures, divestitures, mergers, acquisitions, capital market transactions, audits, litigation, intellectual property and strategic corporate tax planning. Before her in-house roles, Unglaub practiced law at the firms of Davis Polk & Wardwell (New York), and Morgan Lewis & Bockius (Philadelphia). Wendy holds her A.B. from Harvard University, JD from Georgetown University Law Center and post-doctorate LLM (Taxation) from New York University School of Law.

Jason Weinstein, Vice President, Tax, North America, Amazon. He and his teams are responsible for all U.S. federal and state as well as Canadian tax planning and tax policy, sales and property tax compliance, and tax-business partnering for Amazon’s North American Stores. Jason and his team also cover worldwide M&A, investments, debt offerings, internal structuring, and other special project areas. Prior to joining Amazon, Jason worked at the law firm Fried, Frank, Harris, Shriver and Jacobson in New York, where he specialized in tax planning for M&A as well as private equity fund formation and strategic joint ventures. Jason has taught tax law at the University of Washington Law School and is a frequent speaker at the usual tax conferences. Jason received his undergraduate degree from Cornell University and his JD, cum laude, from the University of Michigan Law School. Prior to law school, Jason served as briefings director for the Governor of New Jersey.

The Tax Committee and the Leadership Team are chaired by John Stowell, SVP of Tax, Incentives and International Financial Reporting at Disney. The 10-member leadership team, among other things, advises the International Tax Counsel on setting Tax Committee priorities, supports tax committee projects and programming, and helps to grow the tax committee network globally. The Tax Committee presently has 450 members. The new members join the other legacy members of the Tax Leadership Team: Daniel Smith, director, international tax planning and policy at Google, Chad Withers, chief tax officer of Caterpillar, Jocelyn Krabbenschmidt, international tax director of Apple, and Tom Roesser, tax policy counsel at Microsoft.

USCIB’s Annual OECD Tax Conference Focuses on Pillars One and Two

Published on June 29, 2022
OECD’s Pascal Saint Amans

Following a landmark OECD/G20 statement and implementation plan announced on October 8, 2021, multinational companies are now facing a global minimum corporate tax on their operations with multilaterally agreed limitations on said tax. The implementation plan at national levels, known as Pillar Two, seeks to address the tax challenges arising from the digitalization of the economy and was endorsed by G20 Finance Ministers and Central Bank Governors at their October 2021 meeting.

Such was the backdrop and main focus of USCIB’s 15th annual OECD International Tax Conference at the Four Seasons in Washington DC earlier this week (June 27-28), where more than 200 tax experts, OECD officials, multinational companies, as well as foreign and domestic government representatives gathered for the two-day event to discuss pressing global tax issues and developments, including Pillars One and Two.

“This conference took place at another critical point in the 2022 OECD timeline for designing Pillars One and Two for consensus in the Inclusive Framework and, eventually, implementation at the national level,” said USCIB Vice President and International Tax Counsel Rick Minor.

According to Itai Grinberg, deputy assistant secretary for multilateral tax office of tax policy at the U.S. Treasury, ““Pillar Two helps level the playing field. It will ensure that all U.S. and foreign headquartered MNCs face a common level of minimum taxation. And in doing so, this deal, as it has come to be, really answers the single most frequently heard international tax policy request made by the U.S. multinational business community for the entire course of the 21st century.”

“The stability of the international tax architecture is at stake here,” said Martin Kreienbaum, director general of international taxation at Germany’s Federal Ministry of Finance. “I think the international tax architecture is the predictability of tax burden for tax payers from a tax payer perspective. But it’s also the avoidance and absence of double and multiple taxation. I think that is the main objective, the main purpose, under which we have the discussions in the inclusive framework.”

Many questions still remain around Pillar One however, especially in terms of better multilateral coordination around multiple and double taxation and how to build trust with tax payers.

“Together with the agreement on October 8, we had a detailed implementation plan with an extremely ambitious political timeline,” reflected Pascal Saint Amans, Director of the OECD Center for Tax Policy and Administration. “Keep in mind that the overall debate and the deal was still concluded against the background of transatlantic tensions with the previous administration and the need to show that we are restoring better relationships among the countries at stake and cooling down on threats of multilateral measures or trade sanctions.”

Other panels during the conference focused on the tax implications of an increased global mobility of workers arising from the pandemic, tax and climate change, a global minimum tax, dispute prevention and resolution, and much more.

USCIB members from Deloitte, Google, Procter & Gamble and Ernst and Young, among others, joined as panelists to contribute their companies’ perspectives on these pressing taxation issues.

More information on the agenda, speakers, and topics of discussion can be found here.

USCIB is the national affiliate of Business at OECD (known as BIAC), the official multi-jurisdictional business advisor the to OECD.

Featured speakers included:

  • 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

In the News: USCIB Quoted in Tax Notes Following OECD Global Tax Update

Published on July 8, 2021

USCIB Vice President for Taxation Policy Rick Minor was quoted in a lead article in Tax Notes on July 6 regarding the significant global tax update statement made on July 5 by the Organization for Economic Cooperation and Development (OECD).

The OECD inclusive framework on base erosion and profit shifting confirmed that 130 of its 139 members have agreed on key elements of the plan, which aims to address the tax challenges of an increasingly digital and globalized economy.

According to the OECD, the 130 countries and jurisdictions represent more than ninety-percent of global GDP.

In the Tax Notes article, Minor said the USCIB’s members will follow the inclusive framework’s progress closely. “I understand the next significant document will be the design and implementation plan mentioned in the statement,” he said. “We should expect consultation with the business community will continue more earnestly now.”

USCIB Tax Committee members Will Morris (PwC) and Robert Stack (Deloitte) were also quoted.

USCIB Joins Coalition to Oppose IRS Proposal to Declare Revenue Procedure Obsolete

Published on October 21, 2020

USCIB joined a coalition of over a dozen other trade associations to submit a letter to the IRS Large Business and International Division, opposing the proposal to declare Revenue Procedure 94-69 (“Rev. Proc. 94-69”) obsolete. According to the letter, under §6662, the general rule is a taxpayer has until the time the taxpayer is first contacted by the IRS and notified that a tax return is under examination to submit an amended tax return or make other adequate disclosures of errors on their originally filed tax return.

The letter states, “Rev. Proc. 94-69 allows taxpayers who are under continuous audit to avoid the imposition of certain penalties by submitting a written statement within 15-days after receipt of an information request from the IRS, describing all items that would result in adjustments if the taxpayer were to file a properly completed amended return. Pursuant to Rev. Proc. 94-69, such written statements are treated as qualified amended returns.”

The letter goes on to give additional reasons Rev. Proc. 94-69 should not be declared obsolete:

  • Without Rev. Proc. 94-69, large taxpayers would be put in the position of either filing an amended return every time they discovered an error on a previously filed return or bearing the risk that penalties may be imposed.
  • Declaring Rev. Proc. 94-69 obsolete ignores the administrative burden it would visit on taxpayers who otherwise are generally required to file amended state income tax returns every time they filed an amended federal return.

Additionally, now is not an appropriate time to abandon the revenue procedure that has been in place and has been working well for over 35 years. The Tax Cuts and Jobs Act (“Act”) caused a sea change in many elements of the Internal Revenue Code and the IRS and Treasury continue to release guidance on these changes almost three years later. Taxpayers continue to digest the myriad changes to the tax laws and, because of the lag between the passage of the Act and the release of published guidance, taxpayers may not have filed their original returns in line with current guidance. For this reason alone, Rev. Proc. 94-69 is not yet obsolete.

The letter closes by urging the IRS to both retain and expand the eligibility for use of Rev. Proc. 94-69.

The letter can be found in full here.

USCIB Submits Comments to USTR on Proposed Digital Services Taxes

Published on July 21, 2020

USCIB provided comments to the United States Trade Representative (USTR) regarding the proposed Digital Services Taxes (DSTs) of several countries, including Austria, Brazil, Czech Republic, India, Indonesia, Italy, Spain, Turkey, the United Kingdom, as well as the European Union.

USCIB’s submission focused on whether these countries violated Section 301 while encouraging the U.S. to seek a multilateral solution.

“The DSTs under investigation are a poor choice to address the tax issues arising from digitalization of the economy and will work against the economic recovery they are intended to help fund,” said USCIB Vice President for Taxation Policy Carol Doran Klein. “Rather, the U.S. should work cooperatively to find an appropriate multilateral solution to taxing the digitalizing economy that does not unduly burden U.S. interests and fosters certainty for business.”

USCIB Tax Expert Featured In International Tax Review’s ‘Global Tax 50’

Published on January 14, 2020

The International Tax Review (ITR) publication released its annual ‘Global Tax 50’ in December, featuring a rundown of the most influential individuals, organizations, geopolitical events and trends in the tax world. Among the Global Tax 50 is USCIB Vice President for Taxation Policy Carol Doran Klein. 

According to ITR, “voices like Doran Klein will be crucial” in 2020.

In her feature, Doran Klein suggested that “the biggest challenge of 2020 will be getting a political deal on digital tax that holds together the unified approach.”

This ninth edition of the ITR’s Global 50 represents the choices of the ITR editorial team, who decided who or what they thought has had the biggest impact on taxation during the past twelve months. Breaking down the entire 50 individually according to the impact they made would require too granular an approach, so the magazine list is ordered alphabetically.

USCIB Urges Treasury to Work With OECD on Digital Taxation

Published on October 8, 2019

In response to the continuing and extensive digitalization of the economy and increasing calls by countries to tax the income of technology companies that earn revenue in a market without necessarily having a traditional physical presence in that market, USCIB sent a letter on October 4 to Secretary of the Treasury Steven T. Mnuchin. The letter urges Secretary Mnuchin to continue to work with the OECD and other countries to achieve the best outcome for U.S. taxpayers, the U.S. Treasury, and the U.S. economy.

“USCIB believes that any fundamental changes to the international tax rules should be achieved through a consensus-based process,” said USCIB Vice President for Taxation Policy Carol Doran Klein.

According to USCIB’s letter, the best place to conduct a consensus-based process is at the OECD where over 130 countries are participating in a project to attempt to achieve consensus on possible new rules applicable to the broad digitalized economy. The United States Treasury has, to date, been an active participant in this project, including serving as vice-chair of the steering group.

USCIB Reports on Public Hearing on Digital Services Tax

Published on August 20, 2019

USCIB submitted comments on August 19 to the Section 301 Committee on the Investigation of France’s Digital Services Tax (DST).  According to USCIB’s taxation and trade policy experts Carol Doran Klein and Eva Hampl, USCIB believes that France’s DST is actionable under Section 301 because it is unreasonable and discriminates against U.S. companies.

USCIB’s comments note that the DST is also inconsistent with France’s obligations under the World Trade Organization (WTO), the U.S.-France Income Tax Treaty, and the Convention of Establishment between the United States and France. USCIB urges USTR to engage toward a negotiated outcome, including through multilateral channels, such as the Organization for Economic Cooperation and Development (OECD) and the WTO.

The Section 301 Committee, chaired by USTR, held a public hearing on Monday. According to Klein and Hampl who attended the hearing, all of the witnesses expressed great support for the work being done at the OECD and the Inclusive Framework process, noting that unilateral measures will undermine the OECD process and make it more difficult to reach agreement. USCIB has been actively engaged at the OECD on this issue, providing business input to governments, to help guide them to a workable multilateral solution.