Michael Plowgian is a principal in the KPMG Washington National Tax office and is the International Tax Policy Lead for the Americas and on the Global Policy Leadership Team. Prior to rejoining KPMG, Michael served as the Deputy Assistant
Secretary for International Tax Affairs at the U.S. Department of the Treasury, where he was responsible for all aspects of international tax policy, including legislative proposals, regulatory guidance, bilateral treaties, and
multilateral negotiations. In that role, Michael served as the top U.S. negotiator to the Organisation for Economic Co-operation and Development (OECD) on its two-pillar tax reform plan.
Prior to Treasury, Michael was a principal in the Washington National Tax International Tax practice at KPMG.
Michael holds a J.D. from Harvard Law School, an M.A. in Law and Diplomacy from The Fletcher School at Tufts University, and a B.A. from Denison University.
Jeff Mitchell is a Senior Adviser with the Centre for Tax Policy and Administration directorate of the Organisation for Economic Cooperation and Development (OECD) in Paris, France. Since joining the OECD in 2019. Jeff has provided
policy and technical advice on the OECD/G20 project on the Digitalisation of the Economy, focusing on Pillar Two. Prior to joining the OECD, Jeff was a Branch Chief in the Office of Associate Chief Counsel (International), Washington,
DC, where he led a team of attorneys responsible for providing guidance related to the Global Intangible Low-Taxed Income (GILTI), subpart F, Passive Foreign Investment Company (PFIC), and related provisions of the U.S. Internal
Revenue Code. Jeff began his career with the Office of Associate Chief Counsel (Income Tax & Accounting), where he focused on issues related to accounting methods, inventories, and Uniform Capitalization. Jeff earned an LL.M.
in Taxation from the University of Florida Graduate Tax Program, a J.D. from the University of Tennessee College of Law, and a B.S. in Accounting from David Lipscomb University.
Bob advises the US companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation
and Development (OECD).
Bob joined Deloitte Tax from the US Department of the Treasury (Treasury), where he was the deputy assistant secretary for international tax affairs in the Office of Tax Policy. While there, he worked directly with the assistant secretary of tax policy
and the international tax counsel in developing and implementing all aspects of US international tax policy, including treaties, regulations, and legislative proposals.
He also was the official representative of the Obama administration for international tax policy and represented the US government at the OECD where he was involved in all aspects of the Base Erosion and Profit Shifting initiative. Prior to joining Treasury,
Bob had more than 25 years of experience in international tax matters, representing both corporations and individuals.
Bob is a member of the executive committee of the US Branch of the International Fiscal Association (IFA) and a frequent speaker at IFA events worldwide. He a member of the advisory committee for the Annual Institute on Current Issues in International
Tax at The George Washington University School of Law. He is a frequent speaker at events sponsored by such organizations as the Tax Executives Institute, the International Bar Association, American Bar Association Tax Section,
and Irish Tax Institute. He presented the Twenty-Second Tillinghast Lecture on International Taxation at the New York University School of Law.
Bob earned his Bachelor of Arts in English education from State University of New York at Albany and his Master of Arts in French language and literature from New York University. He went on to obtain his Master of Science in foreign service from Georgetown
University and a Juris Doctor from Georgetown University Law Center, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for
the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.
Isaac Wood is an attorney-adviser in the Office of Tax Policy at the U.S. Department of the Treasury. Isaac serves as U.S. delegate to the OECD’s Working Party 11 which carries out the technical work on the Pillar Two global minimum
tax. Prior to joining the Treasury Department, Isaac was in private practice and clerked at the U.S. Court of the Appeals for the D.C. Circuit. Isaac received both his J.D. and undergraduate degree from the University of Virginia.
He is a member of the D.C. Bar (Active member) and Virginia State Bar (Associate member).
Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. Mr. Odintz represents clients before the U.S. Department of the
Treasury, Internal Revenue Service U.S. Congress and the Organisation for Economic Co-operation and Development (OECD). He assists clients in seeking legislative and regulatory changes to tax laws, as well as monitoring key
legislative and regulatory developments. Significant issues include OECD Pillars One and Two, GILTI, BEAT, FDII, foreign tax credits, debt versus equity, the deductibility of research expenses, interest limitations, mark-to-market
on financial products, FATCA, the Common Reporting Standard, the Build Back Better Act, and the Inflation Reduction Act. He also advises clients on domestic and international tax controversy matters at all phases, from audit
and administrative appeals through litigation. Mr. Odintz has experience handling cases involving methods of accounting, transfer pricing, Section 199, research credit, tax accounting, attorney-client privilege and work product,
among others. Mr. Odintz works with multinational businesses to structure their inbound and outbound investments, including in light of the significant changes under OECD/G20 Pillar Two. In addition, Mr. Odintz has held high-level
government positions with the U.S. Department of the Treasury and the Senate Committee on Finance. He previously served as a senior advisor for tax reform to the assistant secretary at the Treasury Department, where he advised
senior treasury officials on tax reform options and issues. Mr. Odintz also served as the chief tax counsel to President Barack Obama's National Commission on Fiscal Responsibility and Reform and was instrumental in formulating
the tax proposals in the commission’s report. Additionally, Mr. Odintz served as the acting tax legislative counsel at the Treasury. Mr. Odintz spends his free time writing tax articles for various publications. He is a frequent
contributor to the Knight Watch column in TAXES magazine, and his most (in)famous article is The TCJA is Not for Losers, which appeared in Bloomberg’s Tax Management International Journal.
Aaron is a partner in PwC's National Tax Services practice based in Washington, DC. His practice focuses on a broad range of international tax matters, including foreign tax credits, cross-border mergers and acquisitions, international
supply chain management, and global treasury operations. He works at the forefront of international tax policy developments, publishing and speaking on the latest OECD initiatives and U.S. legislation and regulations. Aaron
also collaborates with taxpayers and consortiums to advocate for changes to current and proposed tax rules, including consulting with government officials at Treasury, IRS, and the Hill. Prior to rejoining PwC in 2018, Aaron
served as a majority tax counsel to the Ways and Means Committee. There he focused on international tax, mergers and acquisitions, and energy-related tax provisions, assisting in the development and passage of the Tax Cuts
and Jobs Act and other tax legislation. Before joining the Committee staff, Aaron worked in PwC’s National Tax Services practice, based in Washington, DC, and at a small public accounting firm in Omaha, Nebraska. Aaron is a
CPA and an attorney. He holds a BSBA in Accounting from University of Nebraska at Omaha, a JD from Creighton University School of Law, and an LLM from Georgetown University Law Center.
John Merrick is a Senior Level Counsel to the Associate Chief Counsel (International) in the Office of Chief Counsel. Prior to joining Chief Counsel, John practiced international tax in the national offices of two accounting firms
in Washington. He also practiced international and corporate tax in Chicago with an accounting firm and a law firm. John holds a BBA in accounting from Loyola University Chicago, summa cum laude, where he also earned his J.D.,
cum laude, and was a member of the Loyola Law Journal. He obtained an LL.M. in Taxation from the De Paul College of Law. He also passed the Certified Public Accountant exam.
Julia Skubis Weber is a partner in Baker McKenzie's Global Tax Practice Group in Chicago. She has been advising US, non-US and multinational corporate and pass-through clients on federal income tax planning matters since 2005.
Julia routinely advises US multinational and foreign-owned clients on cross-border tax issues, including internal reorganizations, structuring of outbound and inbound investments, foreign tax credits, subpart F, GILTI, withholding and treaty analysis.
In addition, she has extensive experience related to mergers and acquisitions, spin-off transactions and joint ventures. Julia has been recognized by Chambers USA and Legal 500 and is a frequent speaker on international tax
topics. She has contributed to Tax Analysts, Corporate Taxation and Tax Executive Magazine and co-authored International Tax Watch, a bi-monthly column in TAXES The Tax Magazine. Julia also teaches the Controlled Foreign Corporations
class as an adjunct professor in Northwestern Pritzker School of Law’s LLM in Taxation Program.
Fireside Chat
Aharon J. Friedman
Director and Senior Tax Counsel for the Federal Policy Group, LLC
Aharon J. Friedman is a Director and Senior Tax Counsel for the Federal Policy Group, LLC where he advises clients on a wide range of regulatory, legislative and tax litigation matters. Aharon is a leading voice on tax, international
law and sovereignty as well as pension policy issues and has written for and been quoted in publications such as the Wall Street Journal, City Journal, the Hill, the Financial Times, and the Boston Globe. A veteran tax
and pension hand in the Executive and Legislative Branches, Aharon has had a distinguished career in government service, most recently as Senior Adviser to the Assistant Secretary for Tax Policy, Dave Kautter, in the Department
of the Treasury. Previously, Aharon was Senior Tax Counsel at the Committee on Ways & Means, where he served four Chairmen and Ranking Members, beginning with Rep. Jim McCrery. Aharon played a key role in the enactment
of numerous pieces of legislation since 2007, including the Tax Cuts and Jobs Act of 2017 under Chairman Kevin Brady. During his more than twelve years at the Committee, Aharon served as lead staffer on a wide variety of
issues. Aharon helped design TCJA’s revamp of America’s international tax rules starting with Chairman Dave Camp’s 2011 Discussion Draft and Tax Reform Act of 2014, and Chairman Paul Ryan’s 2015 revisions. Aharon has also
been a leader on pension and retirement policy, covering both the Tax Code and ERISA, across the jurisdictions of Treasury, the Department of Labor and the Pension Benefit Guaranty Corporation. A native of Brooklyn, Aharon
earned a B.A. in Economics from Brooklyn College, CUNY, a J.D. from Harvard Law School, an M.P.A. from Harvard’s Kennedy School of Government, and an LL.M. from New York University where he was a Graduate Editor of the
Tax Law Review. Prior to Congress, Friedman was an associate at Shearman & Sterling in New York and Covington & Burling in Washington. Following law school, he clerked for Justice Tova Strasberg-Cohen on Israel’s
Supreme Court in Jerusalem.
Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. Mr. Odintz represents clients before the U.S. Department of
the Treasury, Internal Revenue Service U.S. Congress and the Organisation for Economic Co-operation and Development (OECD). He assists clients in seeking legislative and regulatory changes to tax laws, as well as monitoring
key legislative and regulatory developments. Significant issues include OECD Pillars One and Two, GILTI, BEAT, FDII, foreign tax credits, debt versus equity, the deductibility of research expenses, interest limitations,
mark-to-market on financial products, FATCA, the Common Reporting Standard, the Build Back Better Act, and the Inflation Reduction Act. He also advises clients on domestic and international tax controversy matters at all
phases, from audit and administrative appeals through litigation. Mr. Odintz has experience handling cases involving methods of accounting, transfer pricing, Section 199, research credit, tax accounting, attorney-client
privilege and work product, among others. Mr. Odintz works with multinational businesses to structure their inbound and outbound investments, including in light of the significant changes under OECD/G20 Pillar Two. In addition,
Mr. Odintz has held high-level government positions with the U.S. Department of the Treasury and the Senate Committee on Finance. He previously served as a senior advisor for tax reform to the assistant secretary at the
Treasury Department, where he advised senior treasury officials on tax reform options and issues. Mr. Odintz also served as the chief tax counsel to President Barack Obama's National Commission on Fiscal Responsibility
and Reform and was instrumental in formulating the tax proposals in the commission’s report. Additionally, Mr. Odintz served as the acting tax legislative counsel at the Treasury. Mr. Odintz spends his free time writing
tax articles for various publications. He is a frequent contributor to the Knight Watch column in TAXES magazine, and his most (in)famous article is The TCJA is Not for Losers, which appeared in Bloomberg’s Tax Management
International Journal.
Laura Williams is a partner in the Washington National Tax Office of PricewaterhouseCoopers LLP. Laura is based in Washington, DC and her practice focuses on international tax, particularly cross-border mergers, acquisitions,
divestitures, and restructurings, attribute planning, and provisions of 2017’s Tax Cuts and Jobs Act. Laura also provides support to PwC’s controversy practice, advising clients and providing thought leadership regarding
IRS practices and procedures.
Before joining PricewaterhouseCoopers LLP, Laura was a managing attorney in the U.S. Department of Treasury’s Office of Chief Counsel for the Internal Revenue Service. Laura was Chief of Branch 4 of the International
Tax Division, which has jurisdiction over cross-border transactions, including application of the international tax rules to subchapter C and subchapter K, and related issues. Laura had oversight of published guidance,
IRS litigation, and certain tax administration such as the issuance of private letter rulings to taxpayers. She served in that role from 2019 to 2023.
Prior to joining the Office of Chief Counsel, Internal Revenue Service, Laura was in Ernst and Young LLP’s International Tax and Transaction Tax Services group located in Washington, DC and Atlanta, GA from 2011
to 2019. She also worked in their assurance practice from 2005 to 2008 prior to attending law school.
Laura received her Juris Doctorate from Georgia State University in Atlanta and her Master of Accountancy and Bachelor of Science, accounting major, from the University of Tennessee in Knoxville. She obtained
her CPA license in Georgia in 2011 and is an active member of the State Bar of Georgia.
Jenny Austin is a partner in Mayer Brown's Chicago office and a member of the Tax Controversy practice. She concentrates her practice on federal tax controversy and litigation, working across all industries, including medical
device, pharmaceutical, health care, retail, and technology companies. She guides clients through all stages of tax controversies, from Internal Revenue Service (IRS) audits to administrative appeals, alternative dispute
resolution proceedings, and litigation. Jenny is prepared to respond to a variety of both domestic and international issues that the IRS audits and challenges. Jenny favors strategies to resolve issues successfully
with the IRS at the earliest possible stage without litigation.
Jenny’s tax controversy experience spans a diverse array of subject matter areas, including: transfer pricing, cross-border acquisition issues, debt-equity issues, settlement agreements, withholding, privileges, summons
enforcement, and penalties. She also has experience with transfer pricing issues at the state level.
Jenny maintains an active pro bono practice, most notably working to exonerate an individual wrongfully convicted of murder through a series of cases heard by the trial court, the Illinois Appellate Court, and the Illinois
Supreme Court [People v. Ortiz, 919 N.E.2d 941 (2009)]. She successfully represented a client before the Illinois Department of Children and Family Services who faced a death by neglect indicated finding. She also has
taught trial skills for prosecutors with the Tanzanian Prevention and Combating of Corruption Bureau in Tanzania.
David Berke is a Special Counsel in the IRS Office of the Associate Chief Counsel (International). Mr. Berke advises on a broad range international tax matters, including both guidance and controversy. Previously, he worked
in private practice on international and corporate tax matters. Mr. Berke received his J.D. from Yale Law School and his B.A. from Columbia University.
José serves as leader of EY’s Americas, International Tax and Transaction Services, and previously as the National Tax Department Leader, drawing on his extensive experience, as well as his formidable tax technical skills. José previously led EY’s International Tax and Transaction Services group in EY’s National Tax Department. More recently, Jose served as the Deputy Assistant Treasury Secretary for International Tax Affairs at the
US Treasury Department. At Treasury, Jose provided advice and counsel on all aspects of international tax policy and guidance, including with respect to income tax treaties and other administrative agreements.
Ethics - Bringing your client into compliance without coloring outside the lines
Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal
and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and
entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes. During her tenure with the Justice Department,
Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal, and appellate sections. Caroline
is former President of the American College of Tax Counsel and former Chair of the Civil & Criminal Tax Penalties Committee of the American Bar Association (“ABA”) Section of Taxation. She served as the ABA
Tax Section’s inaugural Vice Chair for Membership, Diversity, and Inclusion, and inaugural Chair of the Loretta Collins Argrett Fellowship Program. Caroline also served as an instructor with the IRS Military Volunteer
Income Tax Assistance program at Ft. George G. Meade.
Rochelle Hodes is a principal in Washington National Tax at Crowe LLP focusing on tax controversy and tax policy. Prior to joining Crowe, Ms. Hodes was Associate Tax Legislative Counsel in the Office of Tax Policy at
the U.S. Treasury Department. While at Treasury, she worked on a variety of matters, including the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (BBA), taxation of digital assets,
and implementation of the Tax Cuts and Jobs Act. She began her career as an attorney with the IRS Office of Chief Counsel. Before returning to Treasury, Rochelle spent several years in private practice. Her experience
includes assisting clients in resolving federal tax disputes, obtaining private letter rulings, and addressing and responding to regulatory and legislative changes in tax policy. Ms. Hodes is a frequent speaker
and author, including a contributing author for the treatise “IRS Practice and Procedure.” In 2017, she was named a ‘Tax Person of the Year’ for 2017 by Tax Notes for her work at Treasury implementing the BBA partnership
audit rules. She received her LL.M from Georgetown University Law Center, her JD from Washington College of Law and her undergraduate degree from the American University. She is a member of the District of Columbia
Bar and a fellow with the American College of Tax Counsel. She is the chair of the Administrative Practice Committee of the Tax Section of the American Bar Association and the immediate past chair of the IRS Advocacy
and Relations Committee of the Tax Section of the American Institute of Certified Public Accountants.
Chris Rizek is a partner in Holland & Knight's Washington, D.C., office who represents taxpayers in all types of federal civil and criminal tax controversy matters. He guides clients through IRS audits, prepares
administrative claims and protests of IRS actions, and litigates tax and tax-related cases in U.S. district and appellate courts, the U.S. Court of Federal Claims, and the U.S. Tax Court. In recent years,
Chris has represented numerous taxpayers, financial entities, and professional firms in connection with IRS examinations of tax shelters and related compliance and professional ethics issues.
Chris formerly
served as a trial attorney with the U.S. Department of Justice's Tax Division, where he received the Outstanding Attorney Award. He also was as an attorney-advisor and then associate tax legislative counsel
with the U.S. Department of the Treasury's Office of Tax Legislative Counsel, with substantial responsibilities for legislation and regulatory actions involving taxpayer rights, tax practice and procedure, and tax
compliance. His combination of practical and policy-level experience in government has given him special insight into the actual application of the tax laws and procedures to taxpayers, which has been of great
value to his clients who are faced with complex tax controversies and litigation.
Chris previously was an adjunct professor in the LL.M. tax program at Georgetown University Law Center and taught a Tax
Practice & Procedure (Administrative) course to IRS personnel. He also has been a guest lecturer at other law schools and universities, and is a frequent speaker at conferences on tax procedure and ethics issues.
Chris was formerly the in-house General Counsel for Caplin & Drysdale, and also served as Chairman of the Ethics Commission in Anne Arundel County, Maryland.
Day 2 Speakers
Recent Tax Cases Affecting International Tax Practice
Michael Caballero is a partner in the Washington office and a vice chair of the Tax Practice Group. His practice focuses on international tax matters, including structural and transactional tax planning, tax controversy, and
tax policy work. Michael previously served as International Tax Counsel in the U.S. Treasury Department’s Office of Tax Policy. While at the Treasury Department, he participated in the development of legislation, regulations,
and administrative guidance concerning all aspects of international tax matters; oversaw the U.S. tax treaty program; and coordinated the representation of the United States in various international fora, including the
Organisation for Economic Co-operation and Development (OECD).
Bill Curran advises on federal income tax aspects of domestic and cross-border M&A deals and global financings and restructurings.
Public and private clients turn to Bill for guidance on the federal income tax
aspects of domestic and cross-border mergers, acquisitions, dispositions, joint ventures and spinoffs. He also advises on financings and restructurings that span the globe.
Saul Mezei is a partner in the Washington D.C. office of Gibson, Dunn & Crutcher and a member of the firm’s Global Tax Controversy and Litigation Practice Group. His practice spans the federal tax controversy area and focuses
on international tax and transfer pricing. He has substantial experience advising clients at all stages of federal tax controversy, from audit and administrative appeals to trial and judicial appeals.
Recent developments in International Taxation with Governmental Update
Danielle is partner in charge of the KPMG Washington National Tax practice, the technical core of the firm’s Tax practice in the United States. She also serves as Tax Policy Lead for the Americas.
Danielle advises multinational clients on the U.S. international tax aspects of their structures, operations, and transactions. In particular, she has extensive experience advising on issues relating to U.S. and global tax policy, tax treaties, expense allocation, source of income rules, and foreign tax credits. She is a frequent speaker on these topics at KPMG and industry events.
Prior to joining KPMG in 2017, Danielle served as International Tax Counsel at the U.S. Treasury Department’s Office of Tax Policy. In that role, she was the principal legal adviser to the Assistant Secretary of Tax Policy and other Treasury officials and led the Office of the International Tax Counsel, whose attorneys provide legal advice and analysis on all international tax issues, including developing and reviewing legislative proposals, promulgating regulations and administrative guidance in consultation with the IRS, and negotiating tax treaties. She also served as a U.S. delegate to the Organisation for Economic Co-operation and Development, with active involvement in the formulation of the policies now referred to as BEPS 1.0.
Prior to joining the Treasury Department, Danielle was a partner at a law firm, where she advised multinational corporations on international tax planning, controversy, and compliance matters.
Danielle received her JD degree, magna cum laude, from Harvard Law School in 2002, where she served as an editor of the Harvard Law Review. Danielle also earned an LLM in taxation, with distinction, from Georgetown University Law Center and a BS degree in accountancy, summa cum laude, from Wright State University. Danielle is a certified public accountant licensed in the District of Columbia and Virginia.
Paul McLaughlin is a Special Counsel in the IRS Office of the Associate Chief Counsel (International). Paul assists the Associate Chief Counsel in providing legal advisory services on all international and foreign tax matters,
including both guidance and controversy. Previously, from 2017 to 2021, Paul served as Legislation Counsel at the Joint Committee on Taxation, where he advised Congress on taxation of business activities and capital markets.
Prior to that, he worked in private practice on a wide range of international and corporate tax matters.
Larissa has a passion for resolving complex tax issues and advises companies in the U.S. and all over the world. Keen analytical skills coupled with practical, straightforward solutions make Larissa an expert in tax structuring,
resolving tax disputes, and negotiating favorable tax transactions. Clients find great value in Larissa’s persistence, technical expertise, and collaborative approach. Larissa is consistently recognized as one of the world’s
leading tax advisors by International Tax Review, Chambers, Euromoney, Legal 500, Daily Journal, Silicon Valley Business Journal and IAE. Chambers has recognized Larissa for her “wide-ranging practice,” with clients noting
that she has "strong international tax expertise," is "a thoughtful and smart tax lawyer" and "brings a lot of insight, and is thorough, responsive and careful." Larissa is one of the World’s Leading Transfer Pricing Advisors
according to ITR. In addition, Larissa enjoys teaching international tax at UC Berkeley, School of Law. Larissa writes a monthly column covering every important recent development in U.S. international tax for Tax Notes International
and speaks at conferences including TEI, IFA, Pacific Rim Tax Institute, Euromoney and the ABA.
Loren Ponds centers her practice on providing strategic counsel to clients on legislative, regulatory, and other tax policy issues, as well as advising on technical tax matters related to transfer pricing and other international
tax topics. She advises clients on the impacts of tax policy, such as the implementation of the Tax Cuts and Jobs Act of 2017 (TCJA) and the Inflation Reduction Act of 2022 (IRA), and issues related to technical corrections,
administrative guidance, and legislative amendments to various provisions. Ms. Ponds has also represented her clients before the Internal Revenue Service (IRS) on international tax controversy matters such as competent authority
claims and transfer pricing audits. Ms. Ponds was described by clients in Chambers USA as "a brilliant tax lawyer. She has in-depth policy experience and is an incredibly well-rounded expert in the matters that matter most
to us." Clients noted she is "very responsive and demonstrates tax technical skills and a deep awareness of how the tax legislative process works on Capitol Hill."
Fireside Chat - Corporate tax insights and pressing issues facing international tax directors
Catherine Schultz is Vice President, Tax and Fiscal Affairs for the Business Roundtable, where she is responsible for tax and advocacy efforts that promote U.S. economic growth, competitiveness and job creation. Before joining
the Business Roundtable, Catherine was the Vice President for Tax Policy at the National Foreign Trade Council for almost 15 years. She was deeply involved in the OECD work on the Base Erosion and Profit Shifting
(BEPS) Project, and the work on the taxation of the digital economy. She is a U.S. representative to the OECD on the WP9 Technical Advisory Group on the taxation of cross-border services under the VAT. She
was also involved in EU and UN tax committee issues that would directly affect the competitiveness of U.S. companies, including the taxation of digital services, withholding taxes based on companies’ gross receipts, and leading
the opposition to the public release of country-by-country reporting information. Schultz was responsible for working with the U.S. Treasury Department and the IRS on regulatory and tax treaty issues.
Ms. Lawrence is Vice President, Global Taxation at Johnson & Johnson corporate headquarters in New Brunswick, N.J. She previously served as Vice President, Tax Planning and Counsel, focusing on international tax planning
for all sectors of the business, as well as mergers, acquisitions, divestitures and licensing transactions.
Prior to joining Johnson & Johnson in 2006, Ms. Lawrence was a tax associate with Dewey Ballantine
LLP in the Washington, D.C. office, focusing on transactional tax, corporate tax planning and bankruptcy matters.
Ms. Lawrence received a Juris Doctor at the University of Virginia School of Law. She
received a Bachelor of Science in Business Administration degree with a concentration in Accounting from the McDonough School of Business at Georgetown University. Ms. Lawrence is a Certified Public Accountant.
Prior to law school, Ms. Lawrence worked as a Senior Tax Accountant in the Real Estate and Financial Services group at Arthur Andersen LLP in Washington, D.C.
Tom Roesser is Tax Policy Counsel for Microsoft Corporation and is a member of Microsoft’s Tax & Customs Leadership Team. Tom’s team is responsible for Tax Modernization, Customs, Tax & Customs Controllership/Center of
Excellence, Policy, and Benefits Taxation. Before joining Microsoft, Tom served as Tax Counsel to the U.S. Senate Committee on Finance and practiced law and accounting. Tom started his career as a certified public accountant
in California and is an attorney licensed to practice in California and the District of Columbia. He holds a Dual LL.M. (with distinction) in Taxation and International and Comparative Law from Georgetown University Law Center,
a J.D. from Loyola Law School in Los Angeles, and a BS in Business Administration (emphasis in accounting) from the University of Southern California. Tom is a Board Member of the International Tax and Investment Center, National
Foreign Trade Council (and former Chair of the Tax Committee), the Tax Council, and the Tax Foundation. He is a Vice-Chair of the International Chamber of Commerce’s Taxation Commission and the U.S. Council for International
Business Tax Committee. Tom is a Vice President of IFA USA, a member of the Central IFA Supervisory Board, and involved in various U.S. and international organizations.
Alfonso Dulcey is a partner in Weil's Tax Department and is based in Miami. Alfonso advises clients on federal income taxation of domestic and cross-border mergers, acquisitions, spin-offs, other disposition strategies, restructurings,
acquisition financing and the use of pass-through entities in acquisitive and divisive transactions, with an emphasis on corporate and international tax planning.
Brian is a partner in the firm's Tax Department and advises multinational corporations doing business in and from Ireland on all aspects of Irish corporate taxation. Brian has a particular interest in cross border tax planning,
transfer pricing and tax controversy matters and also has extensive experience in structuring mergers and acquisitions and corporate reorganisations. Brian’s clients include many of the leading multinational corporations operating
in the ICT, life sciences, manufacturing, retail and industrial sectors in Ireland. Brian also advises on Irish stamp duty matters particularly in the context of global reorganisations. Brian frequently publishes articles in
leading tax journals and is Chartered Tax Advisor and a member of the Law Society of Ireland.
Stuart Landsberg is an Australian international tax partner currently on assignment to PwC US and based in New York. Stuart has over 18 years of tax advisory experience, including over 9 years as a partner. With degrees in accounting
and law, and as a qualified chartered accountant, Stuart has a broad-tax advisory practice - however, he particularly specialises in advising on the tax aspects of mergers and acquisitions, and all tax aspects relating to cross-border
investment and transactions. Over the course of his four years on assignment to the United States, he has particularly focused on advising US clients on how best to navigate the Australian tax system, including advising on
transactions, holding structures, responding to changing judicial and administrative guidance and resolving disputes with the Australian Taxation Office (ATO). Stuart advises clients in a range of industries, including financial
sponsors and sovereign wealth funds, technology, life science and pharmaceutical companies and he has maintains a deep specialisation advising energy, resources and infrastructure companies. His recent experience, particularly
whilst on assignment to the US, has included a particular emphasis advising financial sponsors in relation to M&A and divestments, and technology companies in relation to intellectual property and holding company strategies.
Michiel specializes in Dutch and international tax structuring for US multinational enterprises and investment funds. He has broad experience in advising US clients on cross-border restructurings, M&A, financing transactions,
international holding structures and withholding tax issues. He frequently advises US companies that want to expand their business operations to Europe. He also counsels many clients on the impact of recent EU and OECD changes
(e.g. ATAD 2 and 3, DAC6 and Pillar 2) on their investment structures. He is a regular speaker at at international tax seminars and conferences, such as Tax Executives Institute, the International Fiscal Association (IFA) and
the American Bar Association (ABA). He publishes and speaks frequently about the impact of Pillar Two on US multinational enterprises with EU business operations.
Patrick Brown is Co-Leader, Washington National Tax Services at PwC. Prior to joining PwC in February 2019, he was Vice President, Tax at GE, serving as both the tax director for GE’s Power business and the director of tax policy
for GE.
Prior to these roles, Pat was a senior international tax counsel for GE corporate and GE Capital, where he primarily focused on GE’s international operations in the Nordic region, EMEA and Canada. In
this role, Pat worked extensively with GE Capital’s Commercial Real Estate, Commercial Finance and Consumer Finance businesses as a technical advisor and planner, focusing particularly on cross-border tax matters. He also had
overall responsibility for GE’s foreign tax credit position and was the principal technical advisor to the tax director of GE on tax policy matters.
Pat joined GE in 2002 from the US Treasury Department, where he
served as attorney-advisor and associate international tax counsel from 1998-2002. During his time at Treasury, Pat focused primarily on international tax analysis, negotiation of tax treaties, and representing the US
government at meetings of the OECD on various tax issues.
Audrey received a B.A. degree from Dartmouth College and a J.D. degree from Vanderbilt University. She served as a law clerk for the Honorable Cornelia G. Kennedy of the United States Court of Appeals for the Sixth Circuit. Following
her clerkship, Audrey was an associate at Foley, Hoag & Eliot in Boston, MA, and at McKee Nelson in Washington, DC. She then became a senior manager at KPMG LLP, where she was a member of the Mergers & Acquisitions
Group of the National Tax Department in Washington, DC. From 2001 through 2005, she was an Attorney Advisor in the Office of Tax Legislative Counsel at the Treasury Department. In that role, she focused on corporate tax and
consolidated return matters.
Audrey joined GE in February of 2006. Her first role at GE was in the International Tax Group at GE Corporate. She then moved to the Mergers and Acquisitions Group and is currently Senior Executive Tax Counsel, Transactional
Planning and M&A at GE Corporate. Her present position focuses on acquisition and disposition transactions as well as internal reorganizations.
With over 30 years of industry experience, Mark has helped many of the country’s most successful enterprises implement all aspects of international taxation. A hallmark of Mark’s career has been leveraging technology to improve
tax department performance. Prior to founding Forte International Tax, Mark held leadership positions at PwC, Ernst & Young, and CliftonLarsonAllen. Mark leads the firm on its mission of achieving global tax minimization
through process efficiency.
Eric Sloan is a partner in the New York and Washington D.C. offices of Gibson, Dunn & Crutcher and a Co-Chair of the Firm’s Global Tax Practice Group. With more than 30 years of broad transactional and structuring experience,
Mr. Sloan is a nationally recognized expert in private equity and partnership taxation, as well as on UP-C IPOs and tax receivable agreements. He advised on the first passthrough portfolio company investments made by four of
the largest U.S. based private equity firms. Mr. Sloan has substantial experience in the formation of domestic and cross-border joint ventures and acquisitions and dispositions of businesses and interests in joint ventures.
He also maintains a broad-based corporate tax practice, having advised on numerous spin-offs and other public and private mergers, acquisitions, and spin-offs. In addition, Mr. Sloan is deeply experienced in obtaining private
letter rulings and closing agreements from the Internal Revenue Service on novel and difficult issues on an expedited basis.
Mr. Sloan is ranked as a leading tax lawyer (Band 1) by Chambers USA: America’s Leading Lawyers for Business. The Best Lawyers in America® recognizes him for Tax and Who’s Who Legal also recognizes Mr. Sloan as an “Expert” in the
area of Corporate Tax as well. Additionally, Mr. Sloan was featured in the Who’s Who Legal inaugural edition of Thought Leaders: USA 2023.
Mr. Sloan-started his legal career as an associate with Irell & Manella in Los Angeles and practiced law in Washington, D.C. before joining Deloitte as a principal, where he was asked to establish and lead Deloitte's National
Office Partnership Taxation group. He received his Juris Doctor from the University of Chicago and an LL.M. with distinction in taxation from Georgetown University Law Center. Mr. Sloan is a member of the District of Columbia
bar and the New York bar.
Amanda Pedvin Varma is a partner in the Washington, D.C. office of Steptoe LLP. She advises multinational businesses across a variety of industries on US federal income tax matters with a focus on international tax, including planning,
controversies, and tax policy issues. Amanda also regularly advises clients on mutual agreement procedures and advance pricing agreements and is a co-author of the treatise International Tax Controversies: A Practical Guide.
Amanda is an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center, where she teaches US International Inbound Tax, a course focusing on the US taxation of foreign persons investing in
the United States.