25th Annual Ernst & Young LLP Taxation of Mining Operations Conferencersvp.ey.com/CSG3/2016/1609/1609-1886951/1609-1886951/files/25th... · 25th Annual Ernst & Young LLP Taxation

25th Annual Ernst & Young LLP

Taxation of Mining Operations Conference2–4 November 2016Belmond Charleston PlaceCharleston, South Carolina

© 2014 Ernst & Young LLP. All Rights Reserved. 1

Taxation of Mining Operations Conference

Taxation of Mining OperationsBasic concepts of mining taxationDay 1 — Wednesday, November 2, 2016

8 CPE credits (50 minute hour)

Time Description Discussion leader

7:30 a.m.—8:15 a.m. Continental breakfast

8:15 a.m.—8:30 a.m. Welcome and introductions Andy Miller/Thomas Minor

8:30 a.m.—9:00 a.m. Mining process overview: • Exploration• Development• Production• Reclamation and closure

Joe Denson/Mike Morris

9:00 a.m.—10:00 a.m. Property concepts:• Mineral interest definitions• Sharing arrangements• Lease transactions

Andy Miller/Courtney Bui

10:00 a.m.—10:15 a.m. Break

10:15 a.m.—11:00 a.m. Exploration and development costs:• Identifying costs • Tax treatment

Joe Denson/LaDeana Hawthorne

11:00 a.m.—12:00 p.m. Operations — Part I:• Pre-requisites for depletion• Depletion and gross income

Mike Morris/Ryan Johnston

12:00 p.m.—1:30 p.m. Lunch

1:30 p.m.—2:30 p.m. Operations — Part II• Depletion — net income limitation• Depletion — planning issues• Inventory, stripping costs, operational issues• Receding face deductions

Joe Denson/Paul Wallace

2:30 p.m.—3:15 p.m. Alternative minimum tax:• Depletion preference• Mine exploration and development• Separate and parallel (or not)?• Planning with AMT

Mike Morris/Bob Allen/ Palina Kucharavenka

3:15 p.m.—3:30 p.m. Break

3:30 p.m.—4:15 p.m. Closure/reclamation/environmental:• Accounting methods in the mining industry• Focus on the TPR — basics

Andy Miller/Ray Brown

4:15 p.m.—5:15 p.m. Income tax accounting and mining operations:• Unique permanent and temporary differences• Tax provision and the AMT• Valuation allowance assessments

Thomas Minor/Andrew Williams

5:15 p.m.—5:30 p.m. Q&A Group

6:30 p.m.—7:30 p.m. Cocktail reception

2



Taxation of Mining OperationsCurrent matters and advanced planningDay 2 — Thursday, November 3, 2016



8:00 a.m.—9:15 a.m. Top business risks impacting the mining and metals industry Andy Miller/Thomas Minor/ Andrew van Dinter/Hugh Donahue

9:15 a.m.—10:15 a.m. US Tax legislative update Jeff Petrich/Greg Matlock

10:15 a.m.—10:30 a.m. Break

10:30 a.m.—11:30 a.m. Overview of 385 regulations Jose Murillo/JD Sammons

11:30 a.m.—1:00 p.m. Lunch

1:00 p.m.—2:30 p.m. Breakout sessions — concurrent sessions:• International tax current topics- planning, BEPs, CBC reporting, etc.• State and local tax current topics• 385 regulations-practical considerations for complying• Accounting methods current topics• Alternative financing — current tax developments in partnerships,

streaming, production payments, etc.

Nick D’Antoni/Brian BurrellNancy Flagg/John HeithausJose Murillo/JD SammonsSusan Grais/Rayth MyersJoe Denson/Greg Matlock/ Kevin Richards

2:30 p.m.—2:45 p.m. Break

2:45 p.m.—3:45 p.m. Captive insurance companies Paul Phillips/Ryan Johnston/ Thomas Minor

3:45 p.m.—4:45 p.m. IRS audit update and issues being raised on examination; update on IRS leadership and organizational matters

Mark Mesler/Paul Judd

4:45 p.m.—5:00 p.m. Wrap-up and Q&A

7:00 p.m.—11:00 p.m. Group event/dinner



Taxation of Mining OperationsDetailed technical matters and updates — concurrent sessionsDay 3 — Friday, November 4, 2016




8:30 a.m.—9:30 a.m. Depletion planning Mike Morris/Joe Denson

9:30 a.m.—9:45 a.m. Break

9:45 a.m.—11:15 a.m. Breakout sessions — concurrent sessions:• International tax current topics — planning, BEPs, CBC reporting, etc.• State and local tax current topics• 385 regulations — practical considerations for complying• Accounting methods current topics• Alternative financing — current tax developments in partnerships,

streaming, production payments, etc.

Nick D’Antoni/Brian BurrellNancy Flagg/John HeithausJose Murillo/JD SammonsSusan Grais/Rayth MyersJoe Denson/Greg Matlock/ Kevin Richards

11:15 a.m.—12:15 p.m. Compliance and reporting in an era of transparency Andrew van Dinter/Mike Morris/ Charles Chaho/Mike Gardner

12:15 p.m.—1:00 p.m. Wrap-up and closing remarks Thomas Minor/Mike Morris/ Andy Miller

4


Plenary session

Wednesday, 2 NovemberBasic taxation of mining operations and planning opportunities This session will lay the foundation for a professional new to the mining and metals industry (and refresh seasoned veterans), as well as outline basic planning concepts. You will be exposed to the tax issues by focusing on the life of a mine. By following the way mining operations are conducted, from prospecting to closure, you will be able to relate the tax treatment and issues to the actual physical operations. Throughout the session, we will introduce a number of tax-planning concepts that are basic to the mining and metals industry.

Topics include:• Basic depletion concepts, including cost and percentage

calculations, as well as planning opportunities; fundamental issues in determining the Section 199 production activities deduction

• The difference between exploration and development, along with planning suggestions for these expenditures

• An explanation of the AMT system along with various planning opportunities in the AMT environment

• Various property concepts used in the natural resources industry, including leases, sharing arrangements and production payments

• Use of partnerships in exploration and development, as well as operations

• Aspects of income tax accounting and related disclosure for mining operations

• Mine reclamation and closure costs, environmental remediation and other accounting method issues

On Wednesday evening, we will have a cocktail reception.

Conference program

Thursday and Friday, 3 and 4 NovemberCurrent matters and advanced planning The plenary sessions are devoted to advanced planning topics in the mining and natural resources area. Presentations include the following:• Top 10 business risks facing the mining and metals industry

— In this discussion, we will take a look at the top 10 business risks identified in our current survey for the mining and metals industries. We will include a discussion of the tax implications associated with these key risks.

• US tax legislative update — Prior to the US presidential elections, we will provide the latest updates to the debate in the United States on business and individual income tax reform. This debate continues to progress with the recent issuance of a blue print for tax reform by House Republicans. We will discuss both latest thinking from Washington on the likelihood and timing for enactment, as well as how these proposals could impact the sector.

• Proposed 385 Regulations — Earlier this year proposed regulations were issued to provide guidance in the characterization of financial instruments as debt or equity. While the rules were ostensibly released to discourse corporate inversions, their application in practice is much broader. We will discuss how the rules will impact mining and metals companies, as well as the latest thinking around the timing for enactment and final form.

• Emerging trends in the use of captive insurance companies — With recent favorable court cases defining what are insurable risks, we’ll discuss how captive insurance companies can be utilized in the mining and metals industry to drive both operational improvements and cash savings.



• IRS audit issues and current developments in controversy management — The IRS continues to actively audit mining and metals companies. We will discuss several issues raised in recent examinations that are unique to the industry. In addition, the session will include a discussion dealing with controversy management. We will also discuss the current developments in alternate dispute resolution and examination management, including pre-filing agreements and the Compliance Assurance Program (CAP).

• Compliance and reporting in an era of transparency — The mining sector is the focus of expanded disclosures associated with payments to governments, as well as the pending reporting rules behind the Dodd Frank sec 1504 rules. The era of transparency is upon the sector, so processes and information systems must be deployed to help collect and analyze the data required to be disclosed or reported.

• Depletion planning — In this session we will discuss planning opportunities around the calculation of percentage depletion, our newly released Depletion Analyzer tool that provides structure and discipline to the identification and delivery of planning strategies in this area, and several success stories illustrating how we’ve been able to partner with our clients to deliver value.

Concurrent sessions

Thursday and Friday, 3 and 4 NovemberDetailed technical matters and updates On both Thursday and Friday, we will offer five concurrent breakout sessions; conference attendees will participate in two (one Thursday and one Friday). The intent of these sessions is to give you an opportunity to share experiences and discuss current trends and issues in smaller group settings. Ernst & Young LLP (US) tax professionals, with experience and insights in the respective areas, will lead the sessions:• International tax current developments — This session will

cover current development in the OECD BEPS project impacting the industry, including the new country-by-country reporting requirements, and also more broadly, trends in international planning and compliance.

• Current developments in state and local tax matters — This session will cover state and local taxes and related indirect taxes with a strong focus for issues and opportunities affecting mining and metals companies. As these are often the largest tax burden to a mining operation, we will highlight current developments and tax planning for all types of state and local tax burdens.

• Accounting methods update — In this breakout session, we will provide an update on accounting methods with a specific focus on methods impacting the mining and metals industry including characterization of mine development costs, tangible property regulations and research and experimentation expenditures.

• 385 Regulations — In this breakout session we will focus on practical considerations of these new proposed regulations and best practices around how to insure compliance in your organization.

• Current developments in alternative financing — There continues to be a resurgence in the use of alternative financing structures within the industry, including master limited partnerships (MLPs) for raising equity capital, production payments and streaming transactions.

Thursday will conclude with a cocktail reception and group dinner.

As we have done with all prior conferences, we will wrap up Friday with a brief plenary question-and-answer session.

6


Presenters

Bob AllenMining Tax Solutions, LLP+1 216 408 7711 [email protected]

Bob started Mining Tax Solutions LLP in 2001 as a tax consulting organization specializing in mining taxation. He is a coauthor of Taxation of Mining Operations and has been a lecturer at EY’s education programs for many years. Bob was a partner in the Ernst & Young LLP’s Cleveland offi ce for 16 years. He also worked for BP America and Cliffs Natural Resources. He is a graduate of Cleveland State University with a BBA in Accounting and is a certifi ed public accountant in Ohio.

Ray Brown+1 864 298 [email protected]

Ray serves as a senior manager in Ernst & Young LLP’s Greenville, SC, offi ce as part of the Quantitative Services group. Ray has seven years of experience in tax consulting with extensive experiences in research credit studies, research and experimentation deduction studies, domestic production activities deduction studies, tax accounting methods, UNICAP, transaction costs analysis, capitalization/depreciation studies, and repair and maintenance studies. Ray serves clients around the Southeast in many industries, including power and utilities, mining and metals, manufacturing, retail, life sciences, and rental real estate.

Courtney Bui+1 205 458 [email protected]

Courtney has more than seven years of experience in public accounting serving both publicly held and privately held clients. She is a Tax Compliance manager in Ernst & Young LLP’s Mining & Metals Center of Excellence, a core group of sector-focused professionals who have deep experiences and technical knowledge in the sector.

She has signifi cant experience managing tax compliance and reporting engagements over the course of her career, including managing a 12,000+ hour tax compliance engagement for a publicly traded mining company with more than 200 returns reviewed annually.

Brian Burrell+1 404 541 [email protected]

Brian is a principal with Ernst & Young LLP’s Transfer Pricing practice based in Atlanta. With over 14 years of transfer pricing consulting experience, Brian has assisted a wide variety of multinational companies to address the complexities of their cross-border intercompany transactions. He has served clients involved in industries ranging from automotive, software and consumer products to paper and forestry products, metals, building products, and electronics.

He has assisted clients to manage the transfer pricing implications associated with complex intercompany transactions, including the license of intellectual property, cost sharing, management services and intercompany fi nancing. He has also assisted clients to resolve transfer pricing issues with the IRS and other tax authorities in the context of transfer pricing audits, advance pricing agreements and appeals.

Charles Chaho+1 214 969 [email protected]

Charles has more than 23 years of professional experience serving multinational clients of Ernst & Young LLP, focusing on global compliance & reporting. He manages the needs of our clients’ global tax and statutory fi nancial obligations, including statutory reporting, income tax compliance, indirect tax compliance, transfer pricing and controversy support services provided by member fi rms of the global EY organization.



Nick D’Antoni+1 704 335 4224 [email protected]

Nick is an International Tax senior manager with Ernst & Young LLP, focusing on core ITS and tax efficient supply chain management with over 10 years of client-serving experience. He has worked on projects involved with international tax planning, transaction tax structuring, and due diligence considerations in the outbound US multinational and inbound foreign multinational space. As part of those projects, Nick has in-depth experience advising clients on ASC 740 income tax accounting issues from an international tax perspective, including permanent reinvestment assertions (formerly APB 23). He also has extensive experience advising on and implementing US international tax compliance and filing requirement matters.

Joe Denson+1 205 458 7650 [email protected]

Joe has more than 10 years of experience in public accounting, serving both publicly held and privately held clients. He has spent the majority of his career in the energy sector, primarily focusing on the mining and metals industry.

Joe assists in leading Ernst & Young LLP’s Mining & Metals Center of Excellence, a core group of sector-focused professionals who have deep experiences and technical knowledge in the sector.

Hugh DonahueFreeport McMoRan Inc. +1 602 366 8522 [email protected]

Mr. Donahue has over 25 years of mining industry tax experience and has been with Freeport-McMoRan, Inc. (FCX) for the past 10 years. Prior to his role at Freeport, he served as Vice President of Tax at Phelps Dodge Mining Company. He received a BSBA in Accounting and Finance from the University of Arizona.

FCX is an international mining industry leader based in North America with large, long-lived, geographically diverse assets with significant proven and probable reserves of copper, gold and molybdenum. FCX, with a dynamic portfolio of operating, expansion and growth projects in the copper industry, is also the world’s largest producer of molybdenum and is a significant gold producer. FCX has its operations in five primary divisions: North America copper mines, South America mining, Indonesia mining, Africa mining and molybdenum operations.

Nancy Flagg+1 414 223 7145 [email protected]

Nancy is an Executive Director in Ernst & Young LLP’s State and Local Indirect Tax practice. She also leads the firm’s State & Local Bankruptcy Tax Services practice. Nancy joined the firm in June of 2001 after 19 years of corporate Fortune 500 tax experience. She has specific skills in the employment, property, and sales and use tax areas, with particular emphasis on bankruptcy tax process and procedure and the analysis and resolution of pre- and post-petition bankruptcy tax issues.

Mike GardnerRio Tinto +1 801 204 2508 [email protected]

Michael is currently Vice President of Tax — Americas for Rio Tinto. He has worked for over 20 years in the finance and tax areas. During his career, he has worked extensively with the US tax regime and tax regimes of numerous other countries. He is currently serving as an industry representative on the US Extractive Industry Transparency Initiative Advisory Committee.

Michael is currently based in Rio Tinto’s Salt Lake City regional center. Prior to returning to Salt Lake City, Michael was based in the London headquarters of Rio Tinto.

8


Presenters

Susan Grais+1 202 327 8782 [email protected]

Susan has more than 20 years of experience in the accounting methods technical area.

She is an executive director in Ernst & Young LLP’s Accounting Methods and Inventory group based in Washington, DC. She provides federal tax consulting services to a diverse range of clients. Susan is primarily responsible for serving as a national leader of federal tax capitalization matters, including depreciation and tangible property rules under Section 263 (a). In this role, Susan has extensive experience working with the health care, manufacturing, real estate, restaurant and retail industries. As a national leader for capitalization, Susan is responsible for leading firmwide initiatives.

LaDeana Hawthorne+1 216 583 3644 [email protected]

LaDeana has eight years of experience in auditing income tax provisions, including four years serving the northeast Ohio marketplace. She has more than five years of compliance experience, primarily related to pass-through entities.

She also has significant experience with private equity, privately held companies, venture capital and financial services and several years of experience servicing northeast Ohio manufacturing clients.

John Heithaus+1 314 290 1350 [email protected]

John leads the Indirect Tax Practice in Missouri and Kansas. He also serves as an Indirect Tax service line leader on clients throughout the Midwest. Based in St. Louis, John’s industry focus includes representation of the firm’s mining, coal, power and utilities, and oil and gas clients, particularly on matters of state and local severance taxes and other natural resource-related assessments.

Ryan Johnston+1 205 226 7466 [email protected]

Ryan has more than five years of experience in public accounting, serving both privately held and publicly held clients. Since joining EY in 2011, Ryan has served the energy sector, primarily focusing on the mining and metals industry.

Ryan is a manager in Ernst & Young LLP’s Mining & Metals Center of Excellence, a core group of sector-focused professionals who have deep experiences and technical knowledge in the sector. In serving the mining and metals industry, Ryan regularly assists companies with tax technical aspects related to the stages of the mining process, including exploration, mine development, depletion, depreciation and closure. Ryan has been involved in the modeling of various tax technical matters such as depletion, Section 468 reclamation and closure, Section 168(k)(4) AMT credit monetization, and volumetric production payments for companies in the mining and metals industry.

Paul JuddBarrick Gold of North America, Inc. +1 801 990 3755 [email protected]

Paul is the North America Regional Tax Director and Tax Officer with Barrick Gold of North America, Inc. He has held that position since May 2004. Prior to joining Barrick in 2004, he was US Tax Director and Tax Officer with Rio Tinto/Kennecott Corporation and prior to that worked with both EY and Arthur Andersen. Paul has practiced in the area of mining taxation for over 20 years and is responsible for US, state and local taxation at Barrick. He is a CPA and has a Master of Accountancy (tax emphasis).



Palina Kucharavenka+1 602 322 3366 [email protected]

Palina is a Tax manager with Ernst & Young LLP and has six years of experience in public accounting, serving a wide range of corporate clients, including multinational natural resources clients. Palina is a member of US Tax Mining & Metals Center of Excellence.

Greg Matlock +1 713 750 8133 [email protected]

Greg is a partner/principal in Ernst & Young LLP’s National Tax Department — Energy (Houston based). Greg also serves as EY’s Americas Energy Tax Leader and as EY’s US Master Limited Partnership Leader, as well as EY’s Energy Fund Center of Excellence Markets Leader. His practice is focused on US federal income tax planning and structuring for business transactions involving partnerships (including master limited partnerships) and corporations, with particular emphasis on energy investments.

Greg has significant experience in advising domestic and international energy companies with respect to transactions and tax structuring throughout the energy spectrum (oil and gas, mining and metals, power and utilities, and renewable investments).

Mark Mesler+1 404 817 5236 [email protected]

Mark joined Ernst & Young LLP in 2000 after a 12-year career representing the IRS. He was a trial attorney for IRS Chief Counsel where he represented the agency before the US Tax and Bankruptcy Courts. He specialized in complex litigation and bankruptcy matters. Mark was also designated a Special Assistant United States Attorney.

Mark leads EY’s Southeast Tax Policy & Controversy Services practice. He represents clients before all levels of the IRS. He also advises our professionals and clients on IRS practice, reportable transactions, penalties, disclosures, bankruptcy and other technical tax issues. Mark is a frequent speaker at legal and accounting seminars on IRS practice, tax litigation and bankruptcy tax issues. He is also the author of several papers on these subjects.

J. Andrew Miller+1 314 290 1205 [email protected]

Andy has more than 30 years of experience serving a wide range of corporate clients. He focuses on corporate tax services, acting as a tax engagement partner for several large, multinational energy and natural resources clients.

Thomas Minor+1 205 226 7407 [email protected]

Thomas has 27 years of experience in public accounting, serving publicly held, privately held and international tax clients. He has significant experience with transitioning and leading income tax co-sourcing engagements for Fortune 500 companies.

Thomas has recently taken over as Ernst & Young LLP’s Mining & Metals Tax Leader for the Americas, where he will coordinate all of our resources in this sector across North and South America, including overseeing our US Tax Mining & Metals Center of Excellence.

10


Presenters

Michael Morris+1 216 583 2930 [email protected]

Michael is a partner in Ernst & Young LLP’s National Tax group focused on providing tax advisory services to companies engaged in extractive industries. Prior to joining EY, Michael held the roles of Vice President Tax and Vice President Finance with Cliffs Natural Resources, a global mining company with major operations in the United States, Canada, Australia and Brazil.

Prior to joining Cliffs Natural Resources, Michael worked in public accounting for approximately 15 years where he primarily provided US international tax services to a variety of US and foreign-owned enterprises.

Jose Murillo+1 202 327 6044 [email protected]

Jose is a National Tax partner and leads Ernst & Young LLP’s International Tax Services group in Washington DC. Jose also serves as the firm’s National Director of Technical Services for the International Tax Services practice. His practice focuses primarily on cross-border acquisitions, dispositions and restructurings.

Prior to his current role, Jose was in the Treasury Department’s Office of Tax Policy, where he assisted with developing international tax policy, Treasury regulations and other guidance and with negotiating income tax treaties.

Rayth Myers+1 202 327 6081 [email protected]

Rayth is a member of Ernst & Young LLP’s Federal Tax Services group in the National Tax Department based in Washington, DC. Rayth has worked primarily on issues concerning installment sales, capitalization and cost recovery of fixed assets and intellectual property, Section 174 like-kind exchanges, Section 165 losses, the recognition of income and expenses, and accounting methods.

Jeff Petrich+1 202 467 8401 [email protected]

Jeff is a member of Ernst & Young LLP’s Washington Council practice, where he provides services related to energy, environmental and natural resource policy issues, including climate change. He has a broad range of experience with congressional legislative, procedural and investigative processes.

Jeff served as Chief Counsel to the House Committee on Natural Resources of the US House of Representatives until January 2008. He worked for the Committee for more than 20 years under Chairman George Miller (D-CA) and Chairman Nick Rahall (D-WV), both ranking members.

Paul Phillips+1 312 879 2898 [email protected]

Paul is a Tax partner in Ernst & Young LLP’s Financial Services Organization with more than 20 years of public accounting experience. Paul serves as the Tax Markets Segment Leader for the Southwest overseeing the firm’s tax service offerings, industry relationships and firm professionals across Texas, Louisiana, Oklahoma, Colorado, Arizona, New Mexico, Arkansas and Mississippi. In addition to his US role, Paul leads EY’s Global Captive Platform, coordinating efforts across various services lines and overseeing the execution and delivery of services in 18 countries.

Paul has coordinated tax services for companies ranging widely in size and complexity, including large global organizations, Fortune 1000 companies, regional and community banks, US domestic insurance companies, and multiple captive insurance enterprises.



Kevin Richards+1 713 750 1419 [email protected]

Kevin is the Co-Leader of the Joint Venture and Partnership Tax Services group of Ernst & Young LLP’s National Tax Department. He resides in Houston. Kevin has an active transactional practice with particular focus on large structured transactions involving partnerships (both domestic and international). Throughout his career, Kevin’s practice has focused heavily on transactions in the natural resource area, applying partnership structures in large corporate acquisitions, dispositions, strategic alliances, cross-border financings, and international joint ventures and restructurings. In addition, Kevin has been heavily involved in developing and implementing master limited partnerships that have served as a very effective means for raising equity capital in the natural resources sector.

JD Sammons+1 404 817 4221 [email protected]

JD has experience with both taxable and tax-free transaction planning and implementation, including Section 355 tax-free spin-offs, internal restructurings, pre-transaction restructuring and post-acquisition integration, buy- and sell-side due diligence, and cross-border planning and restructuring.

His experience covers a broad range of areas of tax law, including subchapter C, consolidated returns, international tax, and state and local tax.

His focus is on internal restructurings and tax-free reorganizations.

Andrew van Dinter+61 3 8650 7589 [email protected]

Andrew is a partner in Ernst & Young ABC Pty Ltd’s Melbourne Tax practice and is EY’s Global Mining & Metals Tax Sector Leader, with more than 25 years of experience providing tax advice to corporates in the mining, energy and utilities sectors.

Paul Wallace+1 817 348 6046 [email protected]

An executive director with Ernst & Young LLP, Paul has served tax clients for more than 20 years . He assists with income tax accounting, tax compliance, corporate and partnership tax issues and provides other tax consulting and advisory services to clients in the oil and gas, mining and metals, engineering and construction, and other industries. He assists with all tax-related client needs and is responsible for quality service delivery and overall client satisfaction.

Andrew Williams+1 919 981 3084 [email protected]

Andrew serves as a Tax manager in the Global Compliance & Reporting group of Ernst & Young LLP. He has worked with the firm in Raleigh for three years, supporting the Assurance team. Prior to that, Andrew worked in Perth, Western Australia, in the Mining & Metals Tax group.

Andrew’s main experiences include corporate tax compliance, preparation and review of tax provisions under ASC 740, tax advisory services relating to stock-based compensation, and domestic and foreign earnings and profits studies.

12


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Notes



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25th Annual Ernst & Young LLP Taxation of Mining Operations Conferencersvp.ey.com/CSG3/2016/1609/1609-1886951/1609-1886951/files/25th... · 25th Annual Ernst & Young LLP Taxation