Day One: Monday, June 24, 2024 8:30 am – 9:00 am: Registration & Check-In 9:00 am – 9:30 am: Welcome & Plenary Opening Keynote, Senior Government (TBC)
- Rick Minor, SVP, International Tax Counsel, USCIB
- Whitney Baird, President and CEO, USCIB
- Manal Corwin, Director, OECD Centre for Tax Policy and Administration (CTPA)
- John Stowell, Chair, USCIB Tax Committee, Head of Global Tax and International Financial Reporting, The Walt Disney Company
9:30 am – 10:20 am: The International Tax Agenda This panel will discuss the status of the international tax agenda. Where are we on the two Pillars, and what else is on the agenda outside of the two Pillars? What issues are governments and MNEs focusing on in the short and long run? How can institutions collaborate with each other in addressing the needs of developed and developing countries?
Moderator: Manal Corwin, Director, OECD Centre for Tax Policy and Administration (CTPA)
Panelists:
- Tim Power, Co-chair, OECD/G20 Inclusive Framework on BEPS
- Scott Levine, Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury
- Carlos Eduardo Protto, Director of International Tax Relations, Ministry of Treasury, Argentina
- Marco Iuvinale, Director of European and International Tax Affairs, Italian Ministry of Economy and Finance
- Barbara Angus, Global Tax Policy Leader, EY
- Michael Plowgian, Partner, KPMG
- Jason Weinstein, Vice President, Tax, North America, Amazon
10:20 am – 10:40 am: Refreshment Break 10:40 am – 12:00 pm: Fostering Growth and Adapting to a Changing Environment (Global Mobility, CIT Simplification, Tax Administration 3.0) Tax systems are primarily aimed at financing public expenditures, but they are also used to promote other public policy objectives, such as equity, and to address social and economic concerns. Investigating how tax systems could best be designed to promote economic growth is a key issue for tax policy making. This panel will discuss how tax policy can foster growth and adapt to a changing environment in the areas of increased global mobility of workers, the re-evaluation of anti-abuse measures intended to achieve broadly similar purposes as Pillar Two, as well as the digital transformation of tax administration.
Moderator: Achim Pross, Deputy Director, OECD CTPA
Panelists:
- Mike Williams, Director of Corporate Tax, HM Treasury
- Silke Bruns, Director for International Taxation, Federal Ministry of Finance, Germany (TBC)
- Mickie Schoch, Director of General Fiscal Policy, Directorate General of Fiscal Affairs, Ministry of Finance, Netherlands (TBC)
- Daniel Smith, Director, International Tax Planning & Policy, Alphabet
- Alan McLean, Chair of Business at OECD (BIAC) Tax Committee
12:00 pm – 1:30 pm: Luncheon and Keynote Address- Barbara Angus, Global Tax Policy Leader, EY
- Peter Blessing, Associate Chief Counsel, International, Internal Revenue Service, U.S. Treasury
1:30 pm – 1:50 pm: The European Commission and International Tax Policy - Gerassimos Thomas, Director-General, Directorate-General for Taxation and Customs Union, European Commission
1:50 pm – 3:00 pm: Developments in Addressing Tax Challenges to the Digital Economy – Amount A This panel will provide a discussion on the status of Pillar One – Amount A. In October 2023, the Inclusive Framework’s Task Force on the Digital Economy approved the release of a text of the Multilateral Convention (MLC), together with related materials. This panel will discuss the main elements of the MLC, as well as the next steps on Pillar One.
Moderator: Achim Pross, Deputy Director, OECD CTPA / Jesse Eggert, Senior Advisor, OECD CTPA
Panelists:
- Scott Levine, Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury
- Claudia Consuelo Vargas Cifuentes, Head of International Taxation Office, Colombia; or Andrea del Pilar Prieto Gonzalez, International Tax Advisor, Colombian Tax Administration (TBC)
- Carlos Eduardo Protto, Director of International Tax Relations, Ministry of Treasury, Argentina
- Tom Roesser, Tax Policy Counsel, Microsoft Corp.
- Tadd Fowler, Senior Vice President, Treasurer and Global Taxes, The Procter & Gamble Company
- Bob Stack, Managing Director, Deloitte
3:00 – 4:30 pm: Transfer Pricing, with focus on Amount B Amount B calls for simplification and streamlining of the application of the arm’s length principle as it applies to in-country baseline marketing and distribution activities. The OECD published the final report on Amount B in February 2024. This panel will discuss the content of that report, as well as further work that will be done in this area.
Moderator: Achim Pross, Deputy Director, OECD CTPA
Panelists:
- Chris Bello, Attorney-Advisor, Tax Legislation, U.S. Treasury
- Tim Power, Deputy Director for Business and International Tax, HM Treasury
- Thulani Shongwe, Acting Senior Manager: African Multi-Lateral Tax Co-Operation, ATAF (TBC)
- Kartikeya Singh, Principal, PwC
- Jessie Coleman, Principal, Washington National Tax, KPMG
4:30 pm – 4:50 pm: Refreshment Break 4:50 pm – 6:00 pm: Tax Certainty outside the Pillars As recognised by G20 Ministers, maintaining and enhancing tax certainty benefits taxpayers and tax administrations alike and is key in promoting investment, jobs and growth. Enhancing tax certainty is one of the main priorities of the OECD Forum on Tax Administration which brings together more than 50 advanced and emerging tax administrations. This panel will discuss the latest developments in tax certainty outside of the Pillars.
Moderator: Sandra Knaepen, Acting Head of the Tax Administration & VAT Division, OECD CTPA
Panelists:
- Japan government speaker (TBC)
- Nicole Welch, Director, Treaty & Transfer Pricing Operations, LB&I, Internal Revenue Service, U.S. Treasury
- Carlos Eduardo Protto, Director of International Tax Relations, Ministry of Treasury, Argentina
- Nate Carden, Partner, Skadden Arps
- Elizabeth Stevens, Member, Caplin & Drysdale
- Arlene Fitzpatrick, Principal, NTD, EY
6:00 pm – 7:30 pm: Evening ReceptionDay Two: Tuesday, June 25, 20248:30 am – 9:00 am: Continental Breakfast 9:00 am – 9:30 am: Day 2 Welcome - Congressional Speaker (TBC)
- Rick Minor, SVP, International Tax Counsel, USCIB
9:30 am – 10:30 am: Pillar Two: Implementation of the Global Minimum Tax, including Administrative Guidance In light of the Global Minimum Tax, which comes into effect in many jurisdictions from the beginning of 2024, this panel will discuss the implementation of the Global Minimum Tax among Inclusive Framework jurisdictions.
Moderator: Achim Pross, Deputy Director, OECD CTPA
Panelists:
- John Peterson, Acting Head of the Cross Border and International Tax Division, OECD CTPA
- Trevor McGowan, Associate Assistant Deputy Minister, Finance Canada (TBC)
- Silke Bruns, Director for International Taxation, Federal Ministry of Finance, Germany, (TBC)
- Japan government speaker (TBC)
- Thulani Shongwe, Acting Senior Manager: African Multi-Lateral Tax Co-Operation, ATAF (TBC)
- Pat Brown, Principal, Washington National Tax Services Co-Leader, PwC
10:30 am – 10:50 am: Refreshment Break 10:50 am – 11:50 am: Global Minimum Tax: Rule Co-ordination, Compliance Approaches, Dispute Prevention and Resolution Enhancing tax certainty is a key element of the Two Pillar Solution to the tax challenges arising from digitalization. The Global Minimum Tax includes several features to improve co-ordination, including qualified status/peer review, an administrative framework that facilitates exchange of information and compliance coordination, as well as tax certainty mechanisms that include the potential for a Multilateral Instrument. This panel will discuss the challenges and opportunities in designing rules and administrative approaches to coordinate compliance, prevent disputes and ensure timely resolution of disputes under the Global Minimum Tax.
Moderator: Marco Iuvinale, Director of European and International Tax Affairs, Italian Ministry of Economy and Finance
Panelists:
- John Peterson, Acting Head of the Cross Border and International Tax Division, OECD CTPA
- Beth Bell, Senior Tax Advisor, Tax Policy, U.S. Treasury
- Mickie Schoch, Director of General Fiscal Policy, Directorate General of Fiscal Affairs, Ministry of Finance, Netherlands (TBC)
- Rafic Barrage, Partner, Tax, Baker & McKenzie
- Kevin Brogan, Partner, KPMG
- Alyson Lawrence, Vice President, Global Taxation, Johnson & Johnson
11:50 am – 12:00 pm: Closing Remarks - Manal Corwin, Director, OECD CTPA
- Rick Minor, SVP, International Tax Counsel, USCIB
- Lily Faulhaber, Vice Dean & Ralph H. Dwan Chair in Taxation, Georgetown University Law Center
12 noon: Conference adjourns