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Global IFA Travelling Lectureship Program 2025
Pillar Two and its ramifications
 

Location:
Holland & Knight
800 17th Street N.W.
Suite 1100
Washington, DC

Agenda:
16:00-16:10 - Registration & coffee
16:10-16:20 - Welcoming words:
• Prof. Guglielmo Maisto (Global IFA President)
• Peter Glicklich (IFA USA President)
• Dirk J. J. Suringa (IFA USA Vice President)
16:20-16:25 - Opening of scientific agenda:
• Prof. Robert J. Danon, Chair of IFA's Permanent Scientific Committee:
introduction of topic, objectives, travelling lecturer and panel composition.
16:25-16:50 - Global Travelling lecturer's presentation:
• Prof. Dr. Joachim Englisch
Opening presentation blending a fundamental and practical international perspective with specific regional considerations. Emphasis will also be on the latest and most important developments, such as for example opened questions or the release of new Agreed Administrative Guidance.
16:50-17:15 - Panel discussion
Follow up panel discussion with all constituencies of IFA (Policy Makers, Tax Administrations, Business and Academia).
17:15-17:30 - Q&A with the floor
Concluding remarks by the Global IFA PSC Representative.
17:30-18:15 - Cocktail Reception

Learn more about the Global IFA TLP 2025 Register
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Moderator: Prof. Dr. Robert Danon, Chair of Global IFA Permanent Scientific Committee

Robert Danon is a tenured Professor of Law ("Professeur ordinaire") at the University of Lausanne (Switzerland), where he heads its Tax Policy Center and leads its research platform dedicated to “Tax Disputes and Investment Arbitration”. He has widely published in all areas of Swiss and international tax law and is in particular the co-editor of forthcoming volumes on "Tax Issues in International Investment Arbitration" (Kluwer) and "Tax Treaty Interpretation in light of the Vienna Convention on the Law of Treaties" (International Fiscal Association)

He also serves as the Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association.

Robert practices Swiss and international tax law as an independent expert with over twenty years of experience. He is widely recognized by professional rankings, for example by Who's Who Legal (WWL) which considers that he is: "the top expert to go to for highly technical matters" thanks to his "proficiency in international tax law".

At the international level, his practical expertise focuses on tax treaties and their interpretation, non-discrimination, abuse of rights by taxpayers and States (including State responsibility), dispute resolution, comparative taxation and transfer pricing. His practice also concentrates on the interaction between investment arbitration and tax-related disputes.

Robert is regularly called to give evidence as an expert witness or to act as a consultant in the framework of domestic and foreign court proceedings, mutual agreement and arbitration procedures, including those involving non-tax agreements such as bilateral investment treaties or the Energy Charter Treaty. He has served as an expert witness in international and comparative tax law in several high-profile arbitration cases under the arbitral rules of the International Centre for Settlement of Investment Disputes (ICSID) and the United Nations Commission on International Trade Law (UNCITRAL).

He is also on the list of possible arbitrators under the mandatory binding arbitration clauses provided by selected bilateral tax treaties.

At the national level, Robert's expertise covers all areas of Swiss tax law with a particular emphasis on corporate taxation, restructurings and the taxation of individuals. His practice extends also to criminal tax law, administrative and constitutional law.

Robert has also been involved in several tax reforms and assists both taxpayers and governments on tax policy matters. He has testified before Parliamentary Committees. For instance, in 2015, he was requested by Switzerland's finance minister to analyze the entire constitutionality of its corporate tax reform designed to comply with the OECD/G20 and EU standards.

Robert holds a PhD in Law (“doctorat en droit”) from the University of Geneva (“summa cum laude”) and an LL.M in International Taxation from the University of Leiden (the Netherlands).

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Speaker: Patrick Brown, Co-Leader of PwC's Washington National Tax Services Practice

Pat Brown is a Partner and Co-Leader of PwC’s National Tax Services practice. He advises clients on all aspects of international and domestic policy.Prior to joining PwC, Pat was Vice President and Counsel, Tax for GE Power and GE Renewables and a GE corporate officer. He was also the director of tax policy for GE.

Prior to joining GE Power, 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. He also had responsibility for the company’s overall foreign tax credit position and was a 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. Prior to joining the Treasury Department, Pat was an associate at Sullivan & Cromwell in New York. Pat received a B.S. in Mechanical Engineering, with highest distinction, from the University of Virginia in 1991 and a J.D. from Georgetown University, magna cum laude, in 1995.

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Lecturer: Prof. Joachim Englisch (Germany)

Prof. Dr. Englisch holds a chair for public law and tax law at Münster University.

His research focuses on International and European tax law covering both, direct and indirect taxation.

Dr. Englisch serves as an advisor in expert groups of the OECD and of the EU Commission since 15 years, and he has given advice also to national governments, NGOs and MPs. He is also a visiting professor in several LL.M. programs.

Dr. Englisch has published several books as well as approx. 200 scholarly articles, and he has given approx. 150 invited presentations.

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Speaker: Chip Harter, Retired: Former Deputy Assistant Secretary, US Treasury Department

L.G. "Chip" Harter is a retired tax attorney. From September 2017 through November 2020, he served the Department of the Treasury as Deputy Assistant Secretary of Tax Policy for International Tax Affairs.

As Deputy Assistant Secretary for International Tax Affairs, Mr. Harter was responsible for all international tax matters at Treasury. He played a central role in representing the Treasury in the legislative process for the Tax Cuts and Jobs Act (TCJA), which was signed into law in December 2017. Mr. Harter then led the development and issuance of an integrated set of regulations to implement the new international provisions of the TCJA, including regulations to implement the Global Intangible Low Tax Income (GILTI) regime, the Base Erosion Anti-Avoidance Tax (BEAT), and the Foreign Derived Intangible Income (FDII) regime.

Mr. Harter also represented the United States in tax negotiations at the Organisation for Economic Cooperation and Development (OECD). At the OECD he led the US delegation in negotiations to revise long-standing international tax rules that provide for the allocation of taxing rights over multinational businesses, including negotiations over the designs of Pillar 1 and Pillar 2.

Prior to joining the Treasury, Mr. Harter served for 18 years as a principal in the Washington National Tax Service of PwC. Prior to joining PwC, Mr. Harter served 18 years, first as an associate and then as a partner, in the international law firm of Baker & McKenzie.

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Speaker: Tom Roesser, Tax Policy Council, Microsoft

Tom Roesser is Tax Policy Counsel for Microsoft Corporation and is a member of Microsoft’s Tax and Customs Leadership Team. Tom’s team is responsible for tax modernization and center of excellence, customs, tax and customs controllership, 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 member of The IFA USA Branch Council, Central IFA Supervisory Board, and various U.S. and international organizations.

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