The 29th Annual Institute on Current Issues in International Taxation

Arnold, Joan C. Partner Pepper Hamilton LLP Joan Arnold is a partner with Pepper Hamilton LLP, resident in the Philadelphia office, where she is the chair of the Tax Practice Group, and focuses her practice on federal and international income tax. Joan has more

than 35 years of significant experience in domestic and cross border M&A, and corporate international tax counseling, including substantial tax experience in the private equity arena.

Joan is the president of the American College of Tax Counsel, vice chair of the Tax Section of the American Bar Association, vice president and a member of

the executive committee of the U.S. Branch of the International Fiscal Association, and on the executive committee of the George Washington/IRS

Annual International Tax Institute.

Joan was highly ranked (Tier1) by Chambers USA: America’s Leading Lawyers for Business in tax law for 2016 and is listed in The Best Lawyers in America and was named the Philadelphia Best Lawyers Tax Lawyer of the Year for

2010. Joan is also included in the Pennsylvania Super Lawyers list and also is listed in The International Who’s Who of Corporate Tax Lawyers, The International Who’s Who of Business Lawyers, Who’s Who Legal International – Corporate Tax.

Before entering private practice, Joan was vice president, associate general tax counsel for Citicorp, a full-time faculty member at Rutgers University School of Law – Camden, and a consultant in international tax to KPMG in its

national office. She holds a B.A. (mathematics) from Wagner College, a J.D. from Villanova University School of Law, and an LL.M. (taxation) from New

York University School of Law.

Bello, Christopher Chief, Branch 6, Associate Chief Counsel (International) Internal Revenue Service Chris Bello is the branch chief for Branch 6 of the Office of the Associate Chief Counsel (International), IRS. Branch 6 is responsible for international transfer pricing as well as a number of other practice areas. Chris was a drafter and

reviewer of the proposed, temporary, and final cost sharing regulations and was the reviewer of the final services regulations. He has been a member of

the U.S. delegation to OECD Working Party No. 6 on the Taxation of

Multinational Enterprises for more than eight years, working on matters including the revision of Chapters I through III of the Transfer Pricing

Guidelines and the addition of Chapter IX, the project on intangibles, and the base erosion and profit shifting project.

Chris obtained an undergraduate degree from Princeton University, a law degree from the University of Virginia School of Law, and an LL.M. in taxation from the University of Florida School of Law Graduate Tax Program. He is a member of the Florida Bar.

Bennett, Mary C. Partner Baker & McKenzie LLP Mary Bennett is a tax partner in Baker & McKenzie’s Washington, DC office, where she advises both U.S. and foreign-based companies on tax policy issues

and assists them with international tax planning and controversy matters. She is the Chair of the Firm’s Global Tax Policy Group.

Mary has more than 35 years of international tax experience, including having

served from 2005 to 2011 as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the OECD’s Centre for Tax Policy & Administration in Paris and earlier in her career as the Deputy International

Tax Counsel of the U.S. Treasury Department. She has been recognized as one of America’s leading tax lawyers by Chambers USA, The International Who’s

Who of Corporate Tax Lawyers, and Euromoney’s Guide to Women in Business Law and Guide to the World’s Leading Tax Advisers.

She is a graduate of Harvard University and Columbia Law School and holds a

master of laws degree in taxation from Boston University Law School.

Brown, Karen B. Donald Phillip Rothschild Research Professor of Law The George Washington University Karen B. Brown is the Donald Phillip Rothschild Research Professor of Law at

the George Washington University Law School, where she teaches courses in Federal Income Taxation, Corporate Taxation, and International Taxation. Before joining the faculty at George Washington University, Professor Brown

was Professor of Law and Associate Dean for Academic Affairs at University of Minnesota Law School and Professor of Law at Brooklyn Law School. She was appointed the Julius E. Davis Professor of Law for 1995-96 at University of

Minnesota.

Professor Brown is co-author of an international tax transactions treatise and

co-editor of books on taxation reform, comparative law, and economic efficiency and tax law. She is editor of a comparative book on regulation of tax avoidance

and co-editor of the General Reports for the 18th Congress of the International Academy for Comparative Law. She has published numerous articles and book

chapters on federal income, corporate, international taxation. She is a member of the American Law Institute, International Academy for Comparative Law,

and the International Fiscal Association.

Brown, Patrick J. Tax Director GE Power & Water Patrick Brown is GE’s Vice President, Tax for GE Power, Energy Connections, and Renewables and is GE’s director for Tax Policy.

Prior to joining GE Power, Pat was a senior international tax counsel for GE corporate and GE Capital, 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 and a J.D. from Georgetown

University, magna cum laude, in 1995.

Caballero, Michael J. Partner Covington & Burling LLP Michael J. Caballero is a tax partner at Covington & Burling LLP in the firm’s

Washington D.C. office. Prior to joining Covington, he spent two and a half years in the Treasury Department’s Office of Tax Policy, from February 2010 to August 2012, first as Deputy International Tax Counsel, and then as

International Tax Counsel. He also spent over five and a half years in the Office of Tax Policy from 1999 through 2004, as an Attorney-Advisor and Associate International Tax Counsel. In between his two stints at the Treasury,

he was an international tax partner in the Washington D.C. office of two global law firms.

Mr. Caballero received a B.S. in Mathematics (with a concentration in Computer Science), magna cum laude, from the University of Notre Dame, a

J.D., cum laude, from the Georgetown University Law Center, and an LL.M. in Taxation from the New York University Law School.

Crispino, Paul J. Senior Director, International Tax United Technologies Corporation Paul J. Crispino is a Senior Director, International Tax, at United Technologies Corporation (UTC). Paul also is the current chair of the Foreign Activities of

U.S. Taxpayers Committee of the American Bar Association. Prior to joining UTC, Paul was an international tax principal with Deloitte Tax’s Washington

National practice and an Associate Tax Legislative Counsel with the U.S. Treasury’s Office of Tax Policy. Paul is a frequent speaker and commentator on U.S. international tax matters.

Culbertson, Robert E. Partner Covington & Burling LLP Rob Culbertson is a tax partner at Covington & Burling LLP, where his practice focuses on international tax planning and controversy resolution. He represents some of the largest US- and non-US- based multinationals in

connection with their structural and transactional tax planning. He also represents clients before the IRS, the U.S. Treasury, and Congress, regarding

audit controversies, rulings, regulations, and legislative issues. A graduate of Yale University and Harvard Law School, Mr. Culbertson served

13 years in the government, including a four-year stint as the Associate Chief Counsel (International) at the IRS from 1991 to 1995. During his tenure as

Associate Chief Counsel, Mr. Culbertson participated in many significant developments in US international taxation, including the revision of the US transfer pricing regulations, the parallel development of new OECD guidelines,

and the development of regulations relating to foreign tax credits, subpart F rules, outbound transfers, conduits, and other international tax issues. Earlier in his career, he was the principal author of regulations under FIRPTA and

Section 367, and he served on the staff of the Joint Committee on Taxation during the development of the Tax Reform Act of 1986.

His recent listings include Chambers Global, Chambers USA, Legal 500 US, Best Lawyers in America, Washington DC Superlawyers, and Who’s Who Legal.

Dicker, Eli J. Executive Director Tax Executives Institute Eli J. Dicker is Chief Tax Counsel to the Tax Executives Institute. He is the

lead technical tax adviser overseeing Institute advocacy efforts and initiatives including those related to pending or proposed tax legislation and regulations, treaties, administrative and judicial pronouncements. He leads a legal team in

the development of position papers, testimony, comment letters and amicus briefs. In addition, he serves as liaison to federal and state administrative and

regulatory authorities including the U.S. Treasury and the Internal Revenue Service. Prior to joining TEI, Eli was employed at Capital One Financial

Corporation, where he led the Tax Accounting and Reporting function, overseeing federal and state tax accounting, reporting and compliance.

Eli’s prior experience also includes service as a tax principal with KPMG LLP and as an attorney-adviser and trial attorney in the Office of the Associate

Chief Counsel (International) and Miami District Counsel office of the Internal Revenue Service.

Eli is also an Adjunct Professor of Law at Georgetown University Law Center where he teaches a Cross-Border Tax Controversy Workshop. Eli holds BA, magna cum laude, and MA degrees (political science) from Queens College, City University of New York, a JD from Northeastern University School

of Law and an LLM (Taxation) from New York University School of Law.

Dorfman, Jeffrey L. Managing Director PricewaterhouseCoopers LLP Jeffrey Dorfman is a managing director in the International Tax Services group

at PwC where he provides advice on foreign currency and other financial products issues. Prior to joining PWC, Jeff was the Chief of Branch 5 in the Office of the Associate Chief Counsel (International) for over twenty years.

Branch 5 has jurisdiction over foreign currency issues, cross border financial products issues including subpart F issues relating to foreign currency, foreign banking issues including §1.882-5, treaty issues such as the authorized OECD

approach under Article 7 and trade or business/ECI issues regarding inbound investment vehicles. Jeff is also the principal author of the section 988

regulations, the 2006 proposed section 987 regulations and the §1.985-8 regulations regarding transition to the euro, among other things.

Erwin, Mark Chief, Branch 5, Associate Chief Counsel (International) Internal Revenue Service Mark Erwin is the Branch Chief in Branch 5 of the I.R.S. Office of Associate Chief Counsel (International). He specializes in the taxation of foreign financial

institutions, foreign currency transactions, and cross-border financial products. Prior to joining Chief Counsel in 2006, Mr. Erwin spent several years

practicing tax law at firms in Washington D.C., including Skadden and Latham & Watkins. Mr. Erwin has a J.D. from New York University (2002), a Ph.D. in

English literature from Princeton University (1998) and a B.A. from Trinity University (1992).

Farmer, F. Scott Partner Morgan, Lewis & Bockius LLP Scott Farmer advises clients on all aspects of international tax planning and controversy with the Internal Revenue Service. His clients include US firms engaged in non-US business activities as well as non-US firms operating within the United States. Scott frequently lectures at the Tax Executives Institute and other tax forums.

He also writes on international tax topics, including “Tax Year Splitters – It's Accrual Method Annual Accounting,” 133 Tax Notes 1491 (Dec 19, 2011). Scott is named one of the country’s leading practitioners in taxation by Chambers

USA, one of the world’s leading practitioners in international tax by Chambers Global, a leader in mergers and acquisitions and cross-border structuring by International Tax Review’s World Tax, and one of the Best Lawyers in America.

Prior to joining Morgan Lewis, Scott was a partner in the corporate practice of

another international law firm. He is a member of the American Bar Association’s Tax Section’s Committee on Foreign Activities of US Taxpayers.

Femia, Rocco V. Partner Miller & Chevalier Chartered Rocco V. Femia is a member of Miller & Chevalier Chartered. Mr. Femia’s

practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving

controversies involving U.S. international tax rules, transfer pricing, and U.S. tax treaties. Mr. Femia routinely advises businesses on Advance Pricing Agreements and mutual agreements under tax treaties.

Mr. Femia is a former Associate International Tax Counsel at the U.S.

Department of the Treasury, Office of Tax Policy. While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters.

Mr. Femia writes and speaks regularly on a variety of international tax and transfer pricing issues, and is a former Adjunct Professor at the Georgetown

University Law Center. Mr. Femia graduated, magna cum laude, from Georgetown University Law Center in 1995. He received his B.A. in Economics

from Duke University in 1991.

Fowler, Tadd A. Vice-President – Global Tax The Proctor & Gamble Company Tadd joined The Procter & Gamble Company in 2005. He is Vice President – Tax Operations and is located in Cincinnati. Prior to joining P&G, he was an

international tax partner with PricewaterhouseCoopers, and spent time with General Electric Company early in his career. Tadd is a member of the AICPA

and State CPA Societies in Kansas and Missouri. Tadd is also a frequent speaker at TEI and other tax and international organizations.

Gall, Phillip Principal Ernst & Young LLP Phillip Gall is a Principal in the Partnership Transaction Planning & Economics

Group in Ernst & Young LLP’s National Tax Department and is located in New York. He focuses on the taxation of partnerships, joint ventures, and limited liability companies. Phillip has significant experience in the formation,

operation, and unwinding of these types of entities for large multinationals and for investment funds in both the international and domestic context.

Phillip also has experience representing clients in connection with federal and

state tax controversies involving partnership tax matters.

Phillip is an Adjunct Professor at New York University School of Law, where he has taught partnership tax courses for a number of years, and is a member of the Executive Committee of the New York State Bar Association Tax Section. He

is also a frequent speaker on partnership tax matters at conferences throughout the country.

Phillip has published the following articles: Phantom Tax Regulations: The Curse of Spurned Delegations (Tax Lawyer, Winter 2003), Partnership

Distributions of Marketable Securities (Tax Notes, Nov. 12, 2007), and most recently, The Mysterious Case of Disappearing Debt in Partnership Transactions (Taxes, March 2012).

Prior to joining Ernst & Young LLP, Phillip was a Co-Managing Principal for the

national partnership tax practice of another Big 4 accounting firm. From 1994 until 2009, Phillip practiced law and became the co-head of the law firm’s tax practice.

Phillip has a B.S.B.A., summa cum laude, from Washington University and a J.D., cum laude, and LL.M. (Tax) from New York University School of Law.

Galler, Linda Professor of Law Hofstra University School of Law Linda Galler is Professor of Law at the Maurice A. Deane School of Law at Hofstra University. She is the lead author of “Regulation of Tax Practice,” published by

LexisNexis as part of its Graduate Tax Series, and is a former chair of the ABA Tax Section’s Standards of the Tax Practice Committee. Professor Galler also is

Senior Tax Counsel to the New York City law firm Curtis, Mallet-Prevost, Colt & Mosle, where she consults in the areas of international taxation, corporate taxation, administrative practice and court procedure.

Harris, Mark D. Senior Tax Counsel The Coca-Cola Company Mark Harris is currently a Senior Tax Counsel with The Coca-Cola Company. Prior to joining The Coca-Cola Company, Mark spent a number of years with Ernst & Young in their Washington, DC national tax office, after starting his career in the Passthroughs and International divisions at the Internal Revenue Service’s Office of Chief Counsel. Mark has held many positions in the Tax Section of the American Bar Association, including two years serving as the Chair of the Foreign Activities of US Taxpayers (FAUST) Committee.

Harter, L.G. “Chip” Principal, WNTP PricewaterhouseCoopers LLP L.G. "Chip" Harter is a principal in the PricewaterhouseCoopers LLP Washington National Tax Practice. His practice focuses on advising multinational

corporations on international tax planning and on tax issues arising with respect to financing transactions and financial instruments. Mr. Harter joined

PricewaterhouseCoopers in 1999 after having practiced tax law with Baker & McKenzie for 18 years.

Mr. Harter is a past Chair of the Financial Transactions Committee of the American Bar Association Section of Taxation. His recent publications include:

“Code Sec. 385 Proposed Regulations Would Vitiate Internal Cash Management Operations,” Vol. 42, No. 4 International Tax Journal, p. 5 (July-August 2016) (with Jared Hermann and Aaron Junge); and "The Devil is in the Details:

Problems, Solutions and Policy Recommendations with Respect to Currency Translation, Transactions and Hedging," Vol. 89, No. 3 Taxes, p. 199 (March

2011) (with John D. McDonald, Ira G. Kawaller, and Jeffry P. Maydew). He is co-author of BNA Portfolio 187, Taxation of Non-Equity Derivatives, and BNA Portfolio 189, U.S. Taxation of Notional Principal Contracts.

Mr. Harter earned a JD from the University of Chicago Law School in 1980, where he was Comments and Articles Editor of the University of Chicago Law Review,

and he graduated magna cum laude from Harvard College in 1977. Following law school, Mr. Harter clerked for the Honorable Thomas R. McMillen, United

States District Judge for the Northern District of Illinois.

Hemel, Daniel Assistant Professor of Law University of Chicago Law School Daniel Hemel is an assistant professor at the University of Chicago Law School, where he teaches tax, administrative law, and torts. Prior to his appointment,

he was a law clerk to Associate Justice Elena Kagan on the U.S. Supreme Court. He also clerked for Judge Michael Boudin on the U.S. Court of Appeals for the First Circuit and Judge Sri Srinivasan on the U.S. Court of Appeals for

the District of Columbia Circuit, and served as visiting counsel at the Joint Committee on Taxation.

Daniel graduated summa cum laude from Harvard College and received an M.Phil with distinction from Oxford University, where he was a Marshall

Scholar. He then earned his J.D. from Yale Law School, where he was editor-in-chief of the Yale Law Journal. His articles have appeared or are forthcoming in the Cornell Law Review, Minnesota Law Review, Tax Law Review, Tax Notes,

Texas Law Review, and University of Chicago Law Review. He blogs at WhateverSourceDerived.com.

Hughes, John Acting Director Advance Pricing and Mutual Agreement Program Internal Revenue Service John Hughes presently serves as Acting Director, APMA. John joined the IRS

in September 2011. Prior to assuming his current assignment, John was Senior International Advisor to the Director, Treaty and Transfer Pricing Operations. John has also been a Senior Manager in APMA. Before joining

the IRS, John worked at the Washington offices of Mayer Brown LLP. John received a JD and an MA (Applied Economics) from the University of

Michigan in 1999.

Huynh, Quyen Associate International Tax Counsel U.S. Department of Treasury Quyen Huynh is an associate international tax counsel in the Office of the International Tax Counsel (ITC) of the U.S. Treasury Department. At Treasury,

she works on a variety of U.S. international tax and income tax treaty matters, with a focus on income tax treaties, withholding and information reporting,

FATCA and intergovernmental agreements to implement FATCA. She is also a delegate to the OECD working parties that focuses OECD’s work on tax treaty

matters and on exchange of information, including the OECD’s Common Reporting Standard.

Prior to joining the ITC, she was a Senior Counsel in the Office of Associate

Chief Counsel (International), where she worked on a broad range of international tax matters, including interpretative income tax treaty issues, foreign trust reporting, cross-border individual taxation matters, and

withholding and information reporting. She has worked extensively with the IRS on the development of a variety of technical implementation projects

related to FATCA, and previously detailed to work for the Deputy Commissioner (International). She has also taught courses as an adjunct professor of law at Georgetown University Law Center.

Ms. Huynh has a B.A. from Mount Holyoke College, a J.D. from the University of San Diego School of Law, and an LL.M. in Taxation from Georgetown

University Law Center.

Jenn, Brian H. Attorney Advisor U.S. Department of Treasury Mr. Jenn joined the Office of the International Tax Counsel in the Treasury

Department's Office of Tax Policy in January 2012. At Treasury, he focuses on a wide range of international tax legal and policy issues, developing regulations and other guidance related to subpart F, foreign currency issues, transfer

pricing, digital economy and cloud issues, and cross-border reorganizations. He is a U.S. Treasury delegate to OECD’s Working Party 6 on Transfer Pricing,

which has responsibility for the development of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and to the OECD’s Task Force on the Digital Economy.

Mr. Jenn earned his B.A. and M.A. (Economics) at Northwestern University and his J.D. at Yale Law School. Prior to joining Treasury, Mr. Jenn worked on

international tax issues at a law firm in Washington, DC, and served at the Council of Economic Advisers (2001-2003) and in the U.S. Senate on the

Chairman’s staff of the Joint Economic Committee (2003-2004).

Kane, Thomas J. Division Counsel, LB&I, Office of Chief Counsel Internal Revenue Service Tom Kane is currently the Division Counsel for the Office of Large Business & International Division Counsel function within the IRS Office of Chief Counsel

in Washington, D.C. Within the IRS, the LB&I Division handles large business and international tax issues. As LB&I Division Counsel, Tom oversees the tax

litigation conducted by the IRS in the U.S. Tax Court and legal advice provided to the IRS by over 300 LB&I attorneys and paralegals located throughout the country. Tom previously served as the Division Counsel with the Tax Exempt &

Government Entities Division Counsel function. Tom received his J.D. degree (with distinction) from The John Marshall Law

School, where he was a member of the law review staff, and has advanced degrees in taxation, international legal studies, and public health.

Kleinberg, Rachel D. Partner Davis Polk and Wardwell LLP Ms. Kleinberg is a partner in Davis Polk’s Tax Department, practicing in the Menlo Park office. Her practice focuses on advice to corporate and private equity fund clients on mergers and acquisitions, joint ventures, spinoffs and

reorganizations, as well as cross-border restructurings. She also has significant experience in the areas of corporate finance and derivatives.

Konza, Mark Deputy Commissioner, International Australian Taxation Office Mark is the Deputy Commissioner responsible for international taxation in the ATO. He leads the development of ATO strategy in response to the base erosion and profit shifting, offshore tax evasion and foreign investment risks. He

represents Australia at various OECD forums, particularly the Taskforce of the Digital Economy.

Koskinen, John Commissioner Internal Revenue Service John Koskinen was nominated by President Obama to be the 48th Commissioner of the IRS and was confirmed by the Senate on December 20,

2013, for a term thatexpires in November, 2017. Previously, Mr. Koskinen served as Non-Executive Chairman of the Board of

Freddie Mac from September, 2008, until February, 2012, except for the six months he served as interim CEO, COO and CFO during 2009. From 2004-08

he was President of the United States Soccer Foundation, the charitable arm of soccer in the United States. Mr. Koskinen earlier served as Deputy Mayor and

City Administrator for the District of Columbia from September 2000 to September of 2003, responsible for the operation of all city departments.

Prior to his service as Deputy Mayor, Mr. Koskinen occupied several positions with the United States Government, including service from 1994 to 1997 as Deputy Director for Management of the Office of Management and Budget,

where, among other duties, he coordinated the work of the Chief Financial Officers, Chief Information Officers and Inspectors General of all Federal

agencies. He also ran the two government shutdowns in 1995. From 1998 to 2000, he served as Assistant to the President and Chaired the President’s Council on Year 2000 Conversion, coordinating the country’s transition into

the new century.

Prior to his most recent service with the U.S. Government, Mr. Koskinen joined the Palmieri Company, which specialized in turnaround management, as Vice President and later served as President and CEO from 1979 to 1993,

participating in the reorganization of the Penn Central Transportation Company, Levitt and Sons, and Mutual Benefit, at the time the largest failed life insurance company in history. Earlier in his career, Mr. Koskinen worked

on the staff of the National Advisory Commission on Civil Disorders (the "Kerner Commission"), represented New York City and Mayor John Lindsey in

Washington, and served as Administrative Assistant for four years for Senator Abraham Ribicoff of Connecticut.

Mr. Koskinen graduated with a JD, Cum Laude, from Yale University School of Law and a BA in Physics, Magna Cum Laude, from Duke University. He studied International Law for one year at Cambridge University in England.

Mr. Koskinen was a trustee of Duke University for 12 years, serving as

Chairman of the Board for three years. He served on the Board of the AES Corporation from 2004-2013 and the Board of American Capital, Ltd. from 2007-2013.

Kurihara, Takeshi Deputy Commissioner for International Affairs National Tax Agency Takeshi Kurihara is Deputy Commissioner for International Affairs, National Tax Agency, Japan since June this year.

He joined Japan’s Ministry of Finance in 1986 and since assumed a wide range of positions within the Ministry. For the past decade at the positions of various

Directors at International Bureau of JMOF, he contributed to formulating JMOF’s international financial policies towards US, Europe and Asia, and

represented Japan’s delegations in a number of international fora including those under the ASEAN+3 Finance Minister’s process (CMIM Task Force, ABMI meeting), the APEC Finance Ministers’ process (Senior Finance Officials’

Meeting), and the Paris Club. He also supervised JICA, JBIC and participated in policy making of Japan’s ODA and non-ODA loans. During his secondement to the Financial Service Agency, he worked for issues of income taxation and

international taxation in the financial sectors.

Prior to the current position, he was Chief Financial Officer and Member of the Board of the Innovation Network Corporation of Japan (INCJ), government sponsored Venture Capital and Private Equity Fund Company and the member

of its Investment and Monitoring Committees.

Mr. Kurihara graduated the University of Tokyo in 1986. He was lecturers at graduate schools (Saitama University, University of Tokyo, etc.) and published a

book titled “French economy under the Euro” (in Japanese in 2005).

Lassman, Bruce Vice-President – International Tax IBM Corporation Bruce joined IBM in 2007 and is in charge of global tax planning. In this role, Bruce develops global tax strategies which involve tax minimization as well as optimizing the mobilization of cash around the globe.

Prior to joining IBM, Bruce spent 9 years as Director of International Tax at

FordMotor Company in Dearborn, Michigan where he had similar responsibilities. Bruce is a seasoned international tax specialist as he also has experience working as an international tax partner at Ernst & Young in Detroit,

Chicago, London and New York. Bruce has presented at the George Washington University annual tax

conference, KPMG/NYU annual lecture series as well as International Fiscal Association programs. He has been quoted as an international tax expert in

the Wall Street Journal and London Financial Times and has appeared on CNN.

Bruce has a B.S. and M.S. in Accounting from the Wharton School and a J.D. from Cornell Law School.

Leska, Timothy J. Partner Pepper Hamilton LLP Timothy J. Leska is a partner with Pepper Hamilton LLP, resident in the Philadelphia office. Mr. Leska focuses his practice on the tax aspects of

complex mergers and acquisitions, both domestic and cross-border, with a specialization in transactions involving the formation, acquisition, operation

and dispositions of partnerships and LLCs. Prior to joining Pepper, Mr. Leska was an attorney in the Office of Chief

Counsel (Passthroughs and Special Industries) for the Internal Revenue Service in Washington, DC.

Lew, Mae Special Counsel, Associate Chief Counsel (International) Internal Revenue Service Mae J. Lew is currently serving as a Special Counsel to the Deputies Associate

Chief Counsel (International) in the Office of Chief Counsel, Internal Revenue Service. Ms. Lew is also one of the U.S. delegates at the Organization for Economic Cooperation and Development (OECD), focusing on global

transparency and exchange of information.

Prior to joining International, Ms. Lew was detailed to Main Treasury, where she handled a number of high profile matters for the General Counsel. Before coming to Washington, D.C., Ms. Lew was a senior attorney in Area Counsel’s

office in Boston, Massachusetts, where she litigated numerous cases in Tax Court and served as a Special Assistant United States Attorney for the Department of Justice in Bankruptcy Court.

Ms. Lew received a B.S. in Accounting from the University of Wyoming, a J.D.,

with honors, from the University of Wyoming College of Law, and an L.L.M. in Taxation from Boston University.

Majure, Kimberly Tan Partner KPMG LLP Kimberly Tan Majure joined the Washington National Tax Practice of KPMG

LLP as a principal in the International Corporate Services Group in 2011. Prior to joining the Big Four firm, Kim worked at Washington, D.C., law firm Miller &

Chevalier Chartered, and before that was a counsel at law firm Skadden, Arps, Slate, Meagher and Flom. She brings extensive experience in foreign tax structuring, tax planning, and other international tax services, as well as

representing clients in IRS audit and appeals proceedings.

Kim holds an LL.M in Taxation from the Georgetown University Law Center, a JD from Harvard Law School, and a BA from the University of Virginia

Mazur, Mark J. Assistant Secretary of Tax Policy U.S. Department of Treasury Mark J. Mazur currently serves as the Assistant Secretary for Tax Policy of the U.S. Department of the Treasury. In this role, he is responsible for developing,

analyzing, and coordinating Treasury's and the Administration's agenda, policies, and guidance on tax issues. Since 2009, Mazur has served as Deputy Assistant Secretary for Tax Analysis, where he advised the Secretary on the

economic analysis work undertaken by Treasury's Office of Tax Policy, including studies and reports.

Prior to joining the Office of Tax Policy, Mazur spent eight years working for the Internal Revenue Service, where he was the Director of Research, Analysis, and

Statistics. Mazur has spent 23 years working for the federal government, including positions at the Congressional Joint Committee on Taxation, the President's Council of Economic Advisors and the National Economic Council

under President Clinton, and the Department of Energy.

Mazur received a B.A. in financial administration from Michigan State University and a Master's degree in Economics and Ph.D. from Stanford University's Graduate School of Business.

McDonald, John D. Partner Baker & McKenzie LLP Mr. McDonald is a partner in Baker & McKenzie, LLP, a member of Baker & McKenzie International, a Swiss Verein. His practice focuses on cross-border mergers and acquisitions, and effective tax rate management through intangibles

migration, foreign tax credit planning, repatriation strategies and subpart F planning.

Mr. McDonald co-authors a bi-monthly column for Taxes Magazine. He has co-authored articles for Tax Analysts, such as All or Nothing Rule Leaves Taxpayers Empty Handed (with Jeff Maydew) and Common Issues Involving Indian Acquisitions, Dispositions and Spin-Offs (with Parul Jain and Shreya Rao). He

also co-authors a tax treatise published by the Research Institute of America entitled U.S. Corporations Doing Business Abroad.

Mr. McDonald authored, A Taxing History: Why Corporate Tax Policy Needs to Come Full Circle and Once Again Reflect the Reality of the Individual as Taxpayer,

94 Taxes 93 (March 2016). He testified before the Senate Finance Committee on May 24, 2016 in connection with corporate integration.

From Fall 2005 to Fall 2006, Mr. McDonald served as a legal advisor to Dr. Anwar

Ul-Haq Ahadi, the then Minister of Finance for the Islamic State of Afghanistan. Mr. McDonald assisted with the preparation of the Afghan Income Tax Manual, preparation of tax rulings, and participation in Paris Club negotiations to

restructure Afghanistan’s debt obligations. Mr. McDonald has a bachelor’s degree in accounting from Marquette University

and has passed the Certified Public Accountant’s exam. Mr. McDonald received his Juris Doctorate from Northwestern University School of Law.

McDonald, Michael Financial Economist, Office of Tax Policy U.S. Department of Treasury Michael McDonald is a financial economist in the Business and International Tax Division of Treasury’s Office of Tax Analysis since 2001. Michael represents

the United States at Working Party 6 (Taxation of Multinational Enterprises) of the OECD’s Committee on Fiscal Affairs, as well as on a number of WP6 and

WP1 (OECD Model Tax Treaty) subsidiary groups. He was Chair of WP6 for the BEPS work on transfer pricing (Action Items 8-10). He is a member of the United Nations subcommittee that drafted the United Nations Practical Manual on

Transfer Pricing for Developing Countries, and is a delegate to the OECD’s Tax and Development Task Force. He has participated in a number of bilateral income tax treaty negotiations.

Prior to joining the Treasury Department, Michael was a transfer pricing

economist in the National Tax Department at Ernst & Young (1996-2001). Prior to working at E&Y, Michael was on the Revenue Estimating Division at Treasury’s Office of Tax Analysis (1988-1996).

Michael received a Ph.D. in economics from Boston College in 1988.

Merrick, John J. Senior Counsel, Associate Chief Counsel (International) Internal Revenue Service John Merrick is a Senior Level Counsel to the Associate Chief Counsel

(International) in the Office of Chief Counsel. Prior to joining Chief Counsel, Mr. Merrick 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.

Mr. Merrick holds a Bachelors in Business Administration 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.

Murray, Fred F. Managing Director, International Tax Services Grant Thornton LLP Fred Murray, B.A., Rice University; J.D. University of Texas at Austin, is currently a Managing Director, International Tax Services in Grant Thornton

LLP, U.S. member of Grant Thornton International Ltd, and is an attorney (District of Columbia, Maryland, New York, and Texas (Board Certified in Tax Law, Texas Board of Legal Specialization), and various federal courts) and C.P.A

(Maryland and Texas). His experience includes public law and accounting practice, and government service as Deputy Assistant Attorney General in the

Tax Division at the U.S. Department of Justice and as Special Counsel to the Chief Counsel for the Internal Revenue Service

He is a former Chair of the U.S. Internal Revenue Service Advisory Council (formerly the Commissioner’s Advisory Group, 1953 – 1998); former Advisor to

the International Tax Working Group of the United States Senate Finance Committee; and a former member, Commissioner’s Advisory Council, Department of Taxation and Finance, State of New York.

Fred serves as an adjunct member of the faculty at Georgetown University Law Center where he teaches courses on international taxation and accounting for

income taxes, Sarbanes Oxley Act of 2002, and other issues for corporate tax advisors. Previously, Fred Murray was also an adjunct professor at the University

of Texas School of Law, Rice University Jesse H. Jones Graduate School of Management, and the University of Houston Law Center. He has also lectured at the New York University School of Law.

He is a former Council Director, governing Council of the American Bar Association Tax Section, and Last Retiring Chair of the Administrative Practice

Committee, among various other positions in the ABA Tax Section. He is a Fellow of the American College of Tax Counsel, and a Life Elected Member of the

American Law Institute, and a member of the Bloomberg BNA International and Transfer Pricing Tax Advisory Board. Murray, Sue Director Competent Authority Services Division

Navarro, Grace Perez Deputy Director, CTPA Organization for Economic Co-operation and Development (OECD) Grace Perez-Navarro is the Deputy Director of the OECD’s Centre for Tax Policy and Administration. As such, she plays a key role in the Base Erosion and

Profit Shifting (BEPS) Project, improving international tax cooperation, tackling illicit financial flows, promoting better tax policies and engaging developing

countries in OECD tax work. Since joining the OECD in 1997, she has held several key positions, including having led the OECD’s work on bank secrecy, tax and e-commerce, harmful tax practices, money laundering and tax crimes,

the tax aspects of countering bribery of foreign officials, and strengthening all forms of administrative cooperation between tax authorities.

Prior to joining the OECD, Ms. Perez-Navarro was a Special Counsel at the IRS Office of the Associate Chief Counsel (International) where she was responsible

for coordinating guidance provided to field offices on international tax issues, overseeing litigation of international tax issues, negotiating TIEAs, overseeing the drafting of regulations, rulings and other policy advice and participating in

treaty negotiations. In 1993, she was seconded by the IRS to the OECD to launch the revision of the OECD’s Transfer Pricing Guidelines.

Nichols, Kevin Senior Counsel to the International Tax Counsel U.S. Department of Treasury Kevin Nichols is a Senior Counsel in the office of the International Tax Counsel at the U.S. Department of Treasury. Previously, Kevin was a counsel at Skadden, Arps, Slate, Meagher & Flom and a senior tax counsel for Zoetis

Inc. Kevin received his J.D. from Georgetown University and his undergraduate degree from Boston College. Kevin is also a certified public accountant and worked earlier in his career as an accountant for

PricewaterhouseCoopers.

O’Donnell, Douglas Commissioner, LB&I Internal Revenue Service Douglas W. O’Donnell is the Commissioner of the Internal Revenue Service’s

Large Business and International (LB&I) Division headquartered in Washington, D.C. In this role, he oversees tax administration activities for corporations, subchapter S corporations, and partnerships with assets greater

than $10 million and is also responsible for administering the tax law that affects individuals with international activity. He serves as the United States Competent Authority in administering the operating provisions of tax

conventions and on sensitive and controversial issues related to treaty negotiations.

Prior to his current executive appointment, Mr. O’Donnell served as the Deputy

Commissioner (International) in LB&I. In this role, he was responsible for planning, developing, directing, and implementing a comprehensive servicewide tax administration program that enhanced compliance with international tax

laws, ensured consistency in taxpayer treatment, continuously improved systems and processes and effectively allocated resources to meet servicewide international tax administration priorities.

Mr. O’Donnell previously served in other executive positions including the

Assistant Deputy Commissioner, International; Director, Competent Authority & International Coordination; Director of International Compliance, Strategy & Policy; Deputy Director, Pre-Filing and Technical Guidance; and the Director of

Field Operations, Heavy Manufacturing and Transportation Industry.

Mr. O’Donnell began his career with IRS in 1986 as a revenue agent in Washington, D.C. He holds a Bachelor’s of Science degree in accounting from the University of Maryland, College Park, and is licensed as a Certified Public

Accountant in the state of Maryland.

Olson, Pamela F. U.S. Deputy Tax Leader & WNTS Leader PricewaterhouseCoopers LLP Pam is a U.S. Deputy Tax Leader and Washington National Tax Services Leader of PwC. In her role with WNTS, Pam leads a team that includes many former senior government officials and policy advisers.

Prior to joining PwC, Pam led the Washington tax practice at Skadden, Arps,

and served as assistant secretary for tax policy at the US Department of the

Treasury.

Pam has represented clients in a broad range of matters, including IRS audits, appeals and litigation; congressional investigations; private letter ruling requests, proposed regulations, and other IRS and Treasury guidance; and in

the legislative process. She has advised clients on tax and social security reform and on the structuring of financing, partnership, and M&A

transactions. She is a frequent speaker on tax, economic and federal budget matters and has testified before several congressional committees, most recently before the Senate Finance Committee on international tax reform.

As assistant secretary for tax policy, Pam had supervisory responsibility for providing the secretary of the treasury with policy analysis and

recommendations for all domestic and international issues of federal taxation,

Telephone:

(202) 414-1401

Fax:

(678) 529-1022

E-mail:

pam.olson@us.

including legislative proposals, regulatory guidance, and tax treaties, and for providing the official estimates of all government receipts for the president’s

budget and treasury cash management decisions. Pam also held positions with the chief counsel’s office of the Internal Revenue Service as special

assistant to the chief counsel, attorney-adviser in the Legislation and Regulations Division and trial attorney in San Diego District Counsel.

In 2000 and 2001, Pam was the first woman to serve as chair of the American Bar Association Section of Taxation. She has served as tax and economic adviser to two presidential campaigns and as tax adviser to the National

Commission on Economic Growth and Tax Reform. She has been included repeatedly in Chambers USA: America’s Leading Lawyers for Business and The

Best Lawyers in America for tax law. Pam served as a Regent of the American College of Tax Counsel and is on the board of several nonprofit organizations. She received the Treasury Department's highest award, distinguished service

awards from the Federal Bar Association and Tax Executives Institute, and delivered both the Lawrence Woodworth and Erwin Griswold annual lectures.

Pam received her B.A., M.B.A., and J.D. from the University of Minnesota.

Oosterhuis, Paul W. Senior International Tax Partner Skadden, Arp, Slate, Meagher & Flom LLP Mr. Oosterhuis is a senior international tax partner in the Washington, D.C.

office of Skadden, Arps, Slate, Meagher & Flom. Mr. Oosterhuis has had extensive experience in international acquisition and disposition transactions, financing arrangements and tax planning for U.S. and foreign-based

multinational corporations. He frequently represents clients on controversy matters, as well as regulations and rulings proceedings, with the Internal

Revenue Service. In addition, he represents clients in intercompany pricing matters, including docketed Tax Court cases and Advance Pricing Agreement negotiations.

He received his B.A. from Brown University and his J.D. Degree from Harvard Law School. After law school he became a Legislation Attorney for the Joint

Committee on Taxation, U.S. Congress, and later served as the Committee's Legislation Counsel. He has served as an Adjunct Professor at Georgetown

University Law Center, where he taught International Taxation in the Master of Taxation graduate law program.

He has lectured at various professional seminars and institutes, has written on a variety of subjects relating to tax matters, and has testified before

congressional tax writing committees on various tax legislative issues. He is a

member of the bar of the District of Columbia and is admitted to practice in the U.S. Tax Court.

Opper, Mark Director, Washington National Tax Deloitte Tax LLP Mark Opper is a principal in the Passthroughs group in the National Tax Office of Deloitte Tax LLP. He works primarily with corporate clients, assisting them

with cross-border partnership transactions including joint ventures, internal restructurings, acquisitions, and dispositions.

Mark speaks and writes frequently on partnership and international tax topics,

and is a regular columnist for the Journal of Passthrough Entities. He also has authored articles that have appeared in Tax Notes, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances

(Practising Law Institute), Journal of Multistate Taxation & Incentives, and other publications. Mark is an active member of the AICPA, serving on the S

Corporation Taxation technical resource panel.

Mark received his B.A. in Economics from the University of Virginia, his J.D. from Wake Forest University, and his LL.M. in Taxation from New York

University.

Parry, Jeffrey Senior Counsel, Associate Chief Counsel (International) Internal Revenue Service Jeffrey Parry is an attorney at the IRS Office of Chief Counsel (International)

where he is a Senior Counsel in Branch 3, which has jurisdiction over the foreign tax credit and expense allocation and apportionment. Prior to joining the Office of Chief Counsel, Mr. Parry practiced tax law in New York as an

associate at Cahill Gordon & Reindel and Paul Hastings. Mr. Parry received his B.A. and B.S., from the University of Utah and his M.

Music from Wichita State University. He received his J.D. from Columbia University School of Law and his LL. M. in Taxation from New York University.

Peroni, Robert J. The Fondren Foundation Centennial Chair for Faculty Excellence and Professor of Law The University of Texas School of Law Professor Robert Peroni practiced law in Chicago and San Francisco and was a member of the Tulane law faculty (from 1981-1989) and the George Washington University law faculty (from 1989-2003) before joining the Texas

law faculty in Fall 2003. He was the first recipient of Tulane's Felix Frankfurter Distinguished Teaching Award. During the 1985-86 academic

year, Professor Peroni served as a professor-in-residence in the Office of Chief Counsel of the IRS. He was a recipient of George Washington University Law

School's Distinguished Faculty Service Award, selected by vote of the 1991 and 1993 graduating classes. He held the title of the Robert Kramer Research Professor of Law while on the G.W. law faculty. Professor Peroni also has

taught as a visiting professor on the law faculties of New York University, the University of Pennsylvania, the University of Texas, UCLA, Northwestern University (where, during the 2002-03 academic year, he served as the J.

Landis Martin Visiting Professor of Law and Business, and, during the Fall 2006 semester, he served as the Jack N. Pritzker Distinguished Visiting

Professor of Law), and Georgetown University. In 2006, Professor Peroni was the recipient of the Texas Exes Faculty Teaching Award for excellence in teaching at the University of Texas School of Law. In 2012, he was appointed

an Adjunct Research Fellow at Monash University’s Department of Business Law and Taxation. Professor Peroni's research and teaching interests are in

the areas of federal taxation, law and economics, international trade, and professional responsibility and legal ethics. He has been the academic co-chair of the Institute’s Advisory Board since 1991, and also is the academic co-chair

of the biennial Parker C. Fielder Oil and Gas Tax Conference, co-sponsored by the IRS and the University of Texas School of Law.

Professor Peroni has co-authored six books, including the three-volume treatise U.S. International Taxation, and has written many articles that appear in a

variety of law journals. He is currently serving as a Vice Chair of the ABA Section of Taxation’s Committee on Foreign Activities of U.S. Taxpayers and

previously served as the Chair of the AALS’ Tax Section. He is a Fellow of the American College of Tax Counsel. Professor Peroni has taught a number of courses in the NYU/IRS Continuing Professional Education program and has

lectured at numerous CLE programs on a variety of legal topics.

Professor Peroni received a B.S.C. degree in Accounting from DePaul University in 1973, a J.D. degree from Northwestern University School of Law in 1976,

and an LL.M. (in Taxation) from New York University School of Law in 1980.

Plowgian, Michael Principal, Washington National Tax KPMG Michael is a principal in KPMG’s Washington National Tax Office for International Tax. He advises multinational corporations regarding international tax planning and policy, with a particular focus on helping clients

address the implications of the OECD/G20 BEPS Project, FATCA, and the OECD/G20 Common Reporting Standard. Michael is a member of the

Business Advisory Group that consults with the OECD regarding the Common Reporting Standard and is an active participant in the ongoing consultations

on BEPS.

Prior to joining KPMG, Michael was a Senior Advisor on Base Erosion and Profit Shifting (BEPS), at the Organisation for Economic Co-operation and

Development (OECD). In that role, he helped lead the OECD work on BEPS and worked with policymakers from OECD and G20 countries to develop the Action Plan on BEPS. Michael was also involved in the development of the

Common Reporting Standard (the “CRS”), a single global standard for automatic exchange of information based on FATCA.

Prior to joining the OECD, Michael was an Attorney Advisor in the Office of the

International Tax Counsel at the U.S. Department of the Treasury. While at Treasury, Michael was a principal drafter of the regulatory guidance and intergovernmental agreements under FATCA. He also served as the Co-Chair of

the OECD’s Treaty Relief and Compliance Enhancement (TRACE) Project, and was the U.S. representative to Working Party 10 on Exchange of Information and Tax Compliance.

Michael is a frequent speaker and moderator at conferences on U.S. international tax issues, including BEPS, FATCA, and the CRS. He is the co-author of the BNA Tax Management Portfolio on U.S. Taxation of Foreign

Investment in U.S. Real Estate, and has published several articles on U.S. taxation.

Porter, Sharon Director, Treaty and Transfer Pricing Operations Internal Revenue Service Sharon Porter is the Director, Treaty & Transfer Pricing Operations within Large Business and International. In this role she has responsibility for

planning, developing, directing, and implementing a comprehensive strategy to address compliance with transfer pricing laws through all forms of

compliance including examination, advanced pricing arrangements, and the mutual agreement program. This organization is also responsible for our effective management of treaty relationships and continuous improvements

to our systems and processes impacting these programs.

She previously served as the acting director, International Business Compliance (IBC) in the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) since July 2014. IBC provides technical

expertise on international tax issues to ensure that multinational business taxpayers comply with their U.S. tax obligations. Areas of focus include withholding, deferral planning, foreign tax credit management, repatriation,

organizations/restructuring, jurisdiction to tax, foreign currency, and inbound financing.

Sharon formerly served as the Director, Field Operations, for International Business Compliance - West, and Director, Field Operations, for International

Individual Compliance and is a graduate of the 2011 Candidate Development Program. Sharon also served as the assistant to the director in Global High

Wealth (GWH) and had responsibility for executive oversight of the workload services area, a newly formed organization focusing on the most complex enterprise structures.

Ring, Diane Professor of Law Boston College Law School Diane M. Ring is a Professor of Law and the Dr. Thomas F. Carney Distinguished Scholar at Boston College Law School, where she researches and writes primarily in the fields of international taxation, ethical issues in

taxation, and corporate taxation. Ms. Ring was the U.S. National Reporter for the 2012 IFA Conference on the Debt-Equity Conundrum, and was the U.S.

National Reporter for the 2004 IFA Conference on Double Nontaxation. Ms. Ring has worked as a consultant to the U.N. on projects regarding treaties and transparency and disclosure for developing countries. Ms. Ring is also co-

author of three case books in taxation – one on ethical issues in federal tax practice, one on corporate taxation, and one on international taxation.

Prior to joining the Boston College Law School, Ms. Ring was an associate professor of law at the University of Florida Levin College of Law, and an

assistant professor at Harvard Law School. Before entering academia, Ms. Ring practiced at the firm of Caplin & Drysdale in Washington, D.C., specializing in the area of international tax and the taxation of financial instruments. Ms.

Ring also clerked for Judge Jon O. Newman of the Second Circuit Court of Appeals. Ms. Ring received her A.B. and J.D. from Harvard University.

Rizek, Christopher S. Member Caplin & Drysdale, Chartered Christopher S. Rizek is a member of the law firm of Caplin & Drysdale, Chartered, in Washington, D.C., and General Counsel of the firm. He formerly served as Associate Tax Legislative Counsel in the U.S. Treasury Department,

Office of Tax Policy, where he helped write tax procedural guidance and legislation, including particularly the Taxpayer Bill of Rights 2 (1996) and the IRS Restructuring and Reform Act of 1998. He has also previously worked in

other Washington law firms and as a Trial Attorney in the U.S. Department of Justice, Tax Division.

Mr. Rizek has a bachelor’s degree in philosophy from Dartmouth College and received his J.D. and his LL.M. in Taxation from Georgetown University Law

Center. He currently is an Adjunct Professor at Georgetown University Law Center, was formerly Chairman of the Anne Arundel County (Maryland) Ethics

Commission, and has chaired committees and served in other capacities in the D.C. Bar’s Taxation Section, the American Bar Association, Section of Taxation, and the American College of Tax Counsel.

Rolfes, Danielle International Tax Counsel U.S. Department of Treasury

Danielle E. Rolfes joined the Treasury Department in August 2011 as the Deputy International Tax Counsel, and has served as the International Tax Counsel since September 2012. The Office of the International Tax Counsel is

the principal legal adviser to the Deputy Assistant Secretary (International Tax Affairs)

and the Assistant Secretary (Tax Policy) on all aspects of international tax policy, including the development and review of legislative proposals, the promulgation

of regulations and administrative guidance, the negotiation of tax treaties, and representing the United States in international organizations such as the

Organisation of Economic Cooperation and Development. Prior to joining the Treasury Department, Ms. Rolfes was a partner, at Ivins, Phillips & Barker, where her practice focused on international tax planning for multinational

corporations.

Ms. Rolfes received her J.D., magna cum laude, from Harvard Law School in 2002, where she served as an editor of the Harvard Law Review. Ms. Rolfes also holds an L.L.M. in Taxation (Georgetown University Law Center, 2005,

with distinction) and a B.S. in Accountancy (Wright State University, 1997, summa cum laude). A certified public accountant, Ms. Rolfes is the author of An Analysis of FIN 48 – Accounting for Uncertain Income Tax Positions

(Matthew Bender, 3d ed. 2009) and a gold medal winner for achieving the highest score on the CPA examination in the State of Ohio. Prior to law school,

Ms. Rolfes was an accountant at Procter & Gamble.

Rollinson, Barbara L. Managing Director Horst & Frisch Barbara L. Rollinson joined Horst Frisch in 1997 to specialize in the economic analysis of transfer pricing issues. She has provided guidance to U.S. and

foreign-based multinational corporations as well as various tax authorities to assist with tax planning, documentation, controversy and Advance Pricing

Arrangements.

Prior to joining Horst Frisch, Dr. Rollinson served as Director of the International Taxation Staff of the U.S. Treasury's Office of Tax Analysis.

During her tenure at Treasury, she led the U.S. Delegation to the Task Force that produced the OECD's 1994 Transfer Pricing Guidelines.

Dr. Rollinson holds a PhD. in Economics from Duke University and a B.A. in Economics from Wellesley College.

Rollinson, Marjorie A. Associate Chief Counsel International (Technical) Internal Revenue Service Marjorie Rollinson was selected as the Associate Chief Counsel (International) in the spring of 2016. She heads the office within counsel of 75 attorneys and other professional responsible for legal advice, guidance, and support to the

IRS, Treasury and the public on international tax issues in all procedural postures. Before becoming the Associate, Ms. Rollinson served as the Deputy

Associate Chief Counsel (International - Technical) from October, 2013 – March 31, 2016.

Prior to joining the IRS, Ms. Rollinson was a principal in EY’s National Tax Department where she was also the National Director of International Tax

Services – Technical and co-chaired the firm’s International Tax Technical Committee.

Ms. Rollinson received her law degree from the University of Maryland in 1987. She received her undergraduate degree from Wellesley College in 1984.

Ms. Rollinson is a member in good standing of the Maryland Bar.

H. David Rosenbloom Member Caplin & Drysdale, Chartered H. David Rosenbloom is the James S. Eustice Visiting Professor of Taxation

and the Director of the International Tax Program at New York University School of Law. He is also a member of Caplin & Drysdale, Chartered, a law firm he rejoined in 1981 after serving as International Tax Counsel and

Director of the Office of International Tax Affairs in the U.S. Treasury Department from 1978 to 1981.

Born in 1941, Mr. Rosenbloom graduated from Princeton University summa cum laude in 1962 and, after a year as a Fulbright Scholar at the University of

Florence in Italy, attended Harvard Law School. He graduated magna cum laude in 1966 and was President of Volume 79 of the Harvard Law Review.

Mr. Rosenbloom served as assistant to Ambassador Arthur Goldberg at the U.S. Mission to the United Nations and then as clerk to U.S. Supreme Court

Justice Abe Fortas.

A frequent speaker and author on tax subjects, Mr. Rosenbloom has taught international taxation and related subjects at Stanford, Columbia, the University of Pennsylvania, Harvard, and New York University Law Schools,

and at educational institutions in Taipei, Mexico City, Milan, Bergamo, Bologna, Sydney, Mainz, Heidelberg, Rio de Janeiro, Pretoria, Melbourne, Vienna, Lisbon, Leiden, and Neuchâtel.

He has also served as Tax Policy Advisor for the U.S. Treasury, the OECD, AID, and the World Bank in Eastern Europe, the Former Soviet Union, Senegal,

Malawi, and South Africa. In recent years he has served as an expert witness on international tax matters in the United States, New Zealand, Canada, Australia, the Netherlands, and Norway.

Sample, William J. Corporate Vice-President – Worldwide Tax Microsoft Corporation Bill is currently responsible for Tax Advisory Services and represents Microsoft to external constituencies on worldwide tax advocacy matters.

Since first entering the software industry in 1989, Bill has been involved with regulatory and legislative efforts particular to the software industry, including

subpart F manufacturing status, revenue characterization & withholding, FSC/ETI/Domestic Production benefits for software revenue, international taxation of e-commerce including participation in the OECD Business Profits

TAG, and the computer software carve-out from the Section 197 intangibles amortization rules. Bill chaired the R&D Credit Coalition, representing a

diverse group of trade associations and companies pursuing a permanent and enhanced R&D tax credit, for 17 years. He is Chair of the USCIB Taxation Committee and a Vice Chair of BIAC, playing a leadership role in the business

consultation and implementation on the OECD’s BEPS project. Prior to entering the software industry, Bill was a senior tax manager at one of

the Big 8 accounting firms. He has an AB in economics from Harvard College, a Master’s of Science in Taxation from Bentley College, and is a licensed CPA.

Setzer, Theodore D. Assistant Deputy Commissioner (International) Internal Revenue Service Ted Setzer is the Assistant Deputy Commissioner (International) within the

Large Business and International Division of the United States Internal

Revenue Service. In this role, he bears responsibility for matters of international policy and protocol within LB&I. He is delegated Competent

Authority status for the United States. He coordinates the IRS’s engagements with multilateral organizations including the Organization for Economic

Cooperation and Development (OECD), the Forum on Tax Administration (FTA), and the Global Forum on Transparency and Exchange of Information for Tax Purposes.

Ted previously served as Director of the Foreign Payments Practice within LB&I. In that role, he was responsible for developing and coordinating LB&I’s

overall international information reporting and withholding tax compliance activities. Prior to joining LB&I, Ted spent nearly ten years in the IRS Office of

Chief Counsel, most recently as Deputy Associate Chief Counsel for Strategic International Programs, where he oversaw his office’s role in negotiating, interpreting, and administering tax treaties and other international

agreements. Ted also represented the Office of Chief Counsel at the OECD and other multinational organizations and played a major role in coordinating the

IRS’s strategy for combating abusive tax shelters. Prior to joining the IRS, Ted practiced law at firms in Washington, D.C. and Phoenix, Arizona. Ted holds a B.S.B.A. from Northern Arizona University (1991), a J.D. from the

University of Arizona (1994), and an LL.M. in taxation from New York University (1995).

Sereti, Rosemary Deputy Commissioner, LB&I Internal Revenue Service Rosemary J. Sereti is the Deputy Commissioner of the Internal Revenue

Service’s Large Business and International (LB&I) Division headquartered in Washington, D.C. In this role, she oversees tax administration activities for

corporations, subchapter S corporations, and partnerships with assets greater than $10 million and is also responsible for administering the tax law that affects individuals with international activity.

Prior to her current executive appointment, Ms. Sereti served as the acting Deputy Commissioner (Domestic) in LB&I. In this role she was responsible for

planning, developing, directing, and implementing a comprehensive servicewide tax administration program that enhanced compliance with tax laws, ensured

consistency in taxpayer treatment, continuously improved systems and processes and effectively allocated resources to meet servicewide tax administration priorities.

Ms. Sereti previously served in other executive positions including the Industry

Director for the Financial Services industry headquartered in New York City; Director, International Individual Compliance; Director, Field Operations

(Manhattan) for the LMSB Financial Services Industry; and the Deputy Director, Pre-Filing and Technical Guidance.

Ms. Sereti began her career with the IRS in 1986 in Massachusetts. She has

held various leadership positions to include Territory Manager in LMSB and Executive Assistant (Operations) to the LMSB Division Commissioner in Washington, DC. She graduated from Quinnipiac College, earned her CPA

designation and received an M.S. degree in Taxation from the University of New Haven.

Smyczek, Jason Senior Technical Reviewer, Branch 4 Associate Chief Counsel (International) Internal Revenue Service Jason Smyczek has been with the IRS, Office of Associate Chief Counsel

(International), Branch 4, since 2009. His work in ACCI includes review of published guidance, PLRs, and providing advice to other IRS employees on

issues relating to the taxation of cross-border transactions. Prior to joining International, Mr. Smyczek spent over seven years as an attorney in Chief Counsel’s Passthroughs and Special Industries Division, where he worked

primarily on partnership tax issues.

Spinowitz, Moshe Partner Skadden, Arps, Slate, Meagher & Flom LLC Moshe Spinowitz is a partner in the Boston office of Skadden, Arps, Slate,

Meagher & Flom. He represents clients on a range of tax matters related to corporate transactions, including public and private company mergers and acquisitions, with a particular emphasis on international tax matters, cross-

border acquisitions, post-acquisition integration and restructuring transactions and supply chain planning.

His practice focuses on clients in the pharmaceutical industry, including both mature pharmaceutical companies and earlier stage companies.

In addition, Mr. Spinowitz advises clients on a range of tax controversy matters during all phases of IRS audits and appeals.

Prior to joining Skadden, Arps, Mr. Spinowitz served as a law clerk to Judge Michael Boudin on the U.S. Court of Appeals for the First Circuit, and as a law

clerk to Associate Justice Antonin Scalia on the U.S. Supreme Court.

Stack, Robert B. Deputy Assistant Secretary International, Office of Tax Policy U.S. Department of Treasury Bob Stack is the Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the US Department of the Treasury. In this capacity, he

is responsible, on behalf of the Assistant Secretary, for the conduct of legal and economic aspects of tax policy relative to the representation of the United

States in bilateral and multilateral relations with other countries, as well as advising the legal and economic staffs within the Office of Tax Policy, other offices of the Treasury Department and other government agencies as to policy

analysis and interpretation for domestic legislation and administrative guidance in all matters involving cross border taxation. Mr. Stack serves as the U.S. delegate to the Committee on Fiscal Affairs (CFA) in the Organization for

Economic Cooperation and Development (the OECD). In addition, Mr. Stack oversees the Office of Tax Policy’s participation in the various working bodies of

the CFA and sits on the CFA Bureau (the CFA’s governing body). Mr. Stack also serves as the U.S. delegate to the Global Forum on Transparency.

Prior to joining Treasury, Mr. Stack served as head of the international tax practice group at the law firm of Ivins, Phillips & Barker. In the private sector,

he has over 26 years of experience in international tax matters, representing both corporations and individuals. His work for corporations has included structuring both inbound and outbound ventures, the establishment of

efficient cross border structures, the formation of joint ventures and private equity funds and all aspects of international mergers and acquisitions.

He is a member of the American Bar Association Tax Section, New York State

Bar Association Tax Section, and International Fiscal Association. Mr. Stack

has participated in numerous panels on international tax issues at the

meetings of the American Bar Association Tax Section as well as the Federal

Bar Association. He graduated from Georgetown University Law Center in

1984, 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.

Stahl, Raymond J. Special Counsel, Associate Chief Counsel (International) Internal Revenue Service Raymond J. Stahl became Special Counsel, ACCI in June 2016. Since joining the Internal Revenue Service in 2011, Mr. Stahl has served as both Assistant to the Branch Chief and Attorney, ACCI Branch 5. Prior to that, he was an attorney with Ropes & Gray LLP.

Mr. Stahl received his JD from Harvard Law School and his BA from Williams College.

Tello, Carol P. Partner Sutherland, Asbill & Brenan LLP With a career that spans both government and private practice, Carol Tello helps multinational companies and individuals navigate the complex and

rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy

matters, including compliance with the Foreign Account Tax Compliance Act (FATCA). Balancing the concurrent goals of minimizing tax consequences and complying with the law, Carol brings experience in cross-border restructuring

transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax

issues involving intellectual property transactions.

Before joining Sutherland, Carol worked in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). She participated in a number of income tax

treaty negotiations, was the IRS National Office adviser in several U.S. Tax Court cases, and worked on various regulations and other guidance, including

significant participation in developing regulations concerning the taxation of software transactions.

Carol is the author of the BNA Treatise “Payments Directed Outside the United States – Withholding and Reporting Provisions Under Chapters 3 and 4.

Vargas, Jacqueline Central Administrator for International Tax Legal Affairs (MAP) Tax Administration Service of Mexico Jacqueline Vargas was born in Mexico City, where she got her degree in

Economics at the Instituto Tecnológico Autónomo de México (ITAM). She also holds a Masters degree from the Université Catholique de Louvain, in Belgium.

Jacqueline has served in several Mexican public offices such as the Ministry of Economics and the National Council for Science and Technology, but most of her

professional career has taken place at the Ministry of Finance, both in the Policy Area as well as in the Tax Administration.

She has experience in different fiscal topics, such as international tax audits, Advanced Pricing Agreements, international legal support and tax policy for the

financial sector.

Varma, Amanda P. Partner Steptoe & Johnson LLP

Amanda Pedvin Varma advises clients on US federal income tax matters, with particular focus on international tax planning and controversies. Her practice includes counseling domestic and foreign businesses with respect to cross-

border acquisitions, business restructurings, and financings, tax treaty matters, deferral and foreign tax credit issues, and transfer pricing. In

addition, she advises clients on withholding and reporting issues, including the Foreign Account Tax Compliance Act (FATCA).

Ms. Varma is also experienced in representing clients in examinations, appeals, and trial and appellate court litigation. She regularly advises clients on special issues arising in international tax controversies and is experienced in matters

involving competent authority and information exchange issues.

Ms. Varma also represents clients in connection with regulatory and legislative tax policy matters. She has advocated for clients with respect to debt/equity issues, tax treaty matters, FATCA, and corporate and international tax reform.

Ms. Varma is the co-chair of Steptoe’s Women’s Forum and a member of the

firm’s Diversity Committee. Her pro bono practice includes representing clients in custody, adoption, and guardianship cases.

Virgadamo, Elena Attorney Advisor U.S. Department of Treasury Elena Virgadamo is an Attorney Advisor in the Office of the International Tax

Counsel at the U.S. Department of the Treasury. At Treasury, she focuses on the tax treaties, exchange of information (including the Foreign Act Tax Compliance Act), and other international tax issues. Prior to joining Treasury,

Elena was an associate in the New York office of Skadden, Arps, Slate, Meagher & Flom LLP, where her practice focused on the tax aspects of mergers and

acquisitions, spin-offs, and fund formation. Elena earned her J.D. at University of California, Berkeley, School of Law (Boalt Hall) and LL.M. in Taxation at New York University.

Yen, Jason Attorney Advisor U.S. Department of Treasury Jason Yen is an attorney advisor with the Office of International Tax Counsel, in the U.S. Department of the Treasury. Mr. Yen focuses on a wide range of international tax legal and policy issues, including foreign tax credits, FIRPTA,

interest expense, and tax treaties. He is also the Treasury Department’s lead delegate to the OECD’s Working Party 11 (Aggressive Tax Planning), which

develops recommendations on hybrids and interest stripping, and the OECD’s Forum on Harmful Tax Practices.

Mr. Yen earned his B.S.E. from Princeton University and his J.D. from Harvard Law School. Prior to joining the Treasury Department, Mr. Yen was an

associate in the Washington, D.C. office of Covington & Burling LLP.

Yoder, Lowell D. Partner McDermott Will & Emery LLP Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery’s Chicago office, and is head of the U.S. & International Tax Practice Group. He

focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech,

pharmaceutical, ecommerce, financial, consumer and industrial companies. He advises on tax efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as

tax beneficial planning for intangible holding companies, global supply chains, and multi-jurisdictional services arrangements. Lowell also represents clients

before the Internal Revenue Service handling audits and obtaining tax rulings. He works with an extensive network of lawyers worldwide developing tax favorable transactional and operational cross-border structures.

Lowell has spoken on a variety of international topics before numerous professional organizations. He is the editor-in-chief of CCH’s International Tax

Journal, and has authored and published numerous articles and treatises on international topics. Lowell was an adjunct professor at the Northwestern

University School of Law, where he taught advanced international taxation. Lowell is an active member of International Committees and Advisory Boards.

He chairs Practising Law Institute’s International Tax Issues. He is a fellow of the American College of Tax Counsel and is USA Branch Counsel of the International Fiscal Association. He is a member of the Planning Committees

for the University of Chicago Law School’s Annual Federal Tax Conference and the GWU/IRS Annual Institute on International Taxation, and on the Advisory

Board of the Tax Management International Journal.

Zent, Brenda L. Special Advisor on International Taxation U.S. Department of Treasury

Brenda L. Zent is a Special Advisor with the U.S. Department of the Treasury's Office of International Tax Counsel. Ms. Zent serves on a small team charged with developing and reviewing policy, legislation, regulations, and similar

guidance dealing with international tax matters. The team also negotiates and reviews income tax and estate and gift tax treaties with foreign countries,

coordinates tax treaty matters with the State Department and the Congress, and handles various inquiries on a variety of international tax matters.

Before joining the Office of International Tax Counsel, Ms. Zent was a managing director in KPMG LLP’s Washington National Tax Corporate practice,

where she specialized in cross-border taxation issues, and also consulted generally on Subchapter C issues. Ms. Zent has also worked in the U.S.

Corporate Tax practice of KPMG’s Toronto, Canada office and in KPMG’s Minneapolis, Minnesota office, providing a full range of federal, international, and state tax consulting.

Ms. Zent has a Bachelor of Accountancy from the University of North Dakota,

and a Master of Business Taxation, from the University of Minnesota. Ms. Zent is a Certified Public Accountant.