Day 2 - Latest Agenda 2025
- Olivia Osier - Tax Manager, KPMG
- Jennifer Acuna - Principal, Washington National Tax Washington, DC, KPMG
- Christopher Groboske - Director, Head of Tax Controversy, AIRBNB
- Ainsley Gaddis - Transfer Pricing Controversy Leader, GE HEALTHCARE
- Nathan Zietlow - Sr. Director, Tax Global Planning, Transfer Pricing, Controversy & Policy, NIKE
- Erik Skarstad - Managing Director, KPMG
- Neil Casey - Partner, KPMG (Ireland)
- Josh McConkey - Managing Director, WNT, KPMG
This session will cover effective methods for handling emerging issues and trends in how tax authorities approach audits in Europe, Middle East and Africa.
- Joseph A. Myszka - Partner, DLA PIPER
- Jason Collins - Partner, DLA PIPER
This session will discuss recent US transfer pricing cases, including the Tax Court’s Facebook opinion and the litany of other transfer pricing cases docketed in Tax Court. We’ll discuss what taxpayers can learn from and need to know about these Cases in order to minimize their own transfer pricing risk.
- Betsy Weiler - Corporate Tax Lead, ZOOM
- Gregor Franz - Associate Director - Transfer Pricing, KRAFT HEINZ
- Joao Braga Ribeiro - Tax Controversy Director, SAMSUNG ELECTRONICS
- Jenny A. Austin - Partner, MAYER BROWN
Recent developments at Treasury and the IRS have impacted nearly every aspect of tax policy and tax administration alike, from regulations to the IRS’s approach to audits of transfer pricing and other issues impacting large corporate taxpayers. Hear from senior in-house tax leaders how these changes are already impacting operations and what corporate tax departments can do to adapt to the new environment.
- Katherine Sakoda - Director, Tax Controversy & Risk Management, KEYSIGHT TECHNOLOGIES
- Barry Dixon - Senior Manager, Tax Controversy, GOOGLE
- Will McGarrity - Head of Global Tax Controversy, NETFLIX
- Rachel Borden - Counsel, MAYER BROWN
- Jason Osborn - Partner, MAYER BROWN
This session will breakdown the components of a typical AI business model and try to identify value drivers and contributions.
- Samuel Mendez - Director of Tax – Transfer Pricing, Economics, ELECTRONIC ARTS
- Prapti Doshi - Director, Transfer Pricing, MICROSOFT
- Lonnie Brist - Sr Managing Director, WNT, KPMG
- Michael Plowgian - Principal, KPMG
- Nicholas Stavrakis - Managing Director, KPMG
The session will provide practical guidance on designing and implementing profit splits, while anticipating and minimizing risks. The session will begin with a review of key features of profit splits, and when profit splits are commonly used. The session will then cover best practices for developing and documenting profit splits, including ensuring there is adequate attention given to documenting the commercial terms of the relevant intercompany transactions. The session will end with an update on US and international case law on profit splits, which should inform how taxpayers approach profit splits and ensure effective maintenance of profit splits.
- William Byrnes - Executive Professor of Law, TEXAS A&M UNIVERSITY SCHOOL OF LAW
- Tamara Levin - Managing Director, ALVAREZ & MARSAL TAX
- Dan Peters - Managing Director & Global Transfer Pricing Leader, ALVAREZ & MARSAL TAX
Join our expert panel as we examine the transfer pricing challenges arising from global mobility. We will discuss the implications of the location of senior decision makers on Permanent Establishments (PEs), the allocation of profits, and emerging risks such as remote work taxation and evolving regulatory scrutiny. Our discussion will provide practical insights on mitigating TP risks, maintaining compliance with local tax authorities, and aligning mobility strategies with OECD guidance, including anticipated updates on this critical issue.
- Juliana Marques - Senior Principal, Tax, AIRBNB
- Himanshu Mishra - Country Head, International Tax and Transfer Pricing, UPS
- Dr. Gene Tien - Vice President, Transfer Pricing, CHARLES RIVER ASSOCIATES
- Patrick O’Gara - Partner, SKADDEN
This session will dive into the congruence of finance and technology and how their interactions impacts intercompany transactions and broadly tax
- Johanna Jumbo - Transfer Pricing Manager Americas, UBER
- Rakhi Bhattacharya - Senior Director, Global Head of Transfer Pricing, FISERV INC.
- Steve Dixon - Partner, DLA PIPER
- Weston Krider - Managing Director, Transfer Pricing Services, KPMG
- Seema Jain - Managing Director, KPMG LLP