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In association with

Delegates,

Welcome to the 13th annual International Tax Review and TPWeek Global Transfer PricingForum, in association with Deloitte.

After 10 years we are back in New York and it is fair to say transfer pricing has changed sig-nificantly since we were last here.

The attention on base erosion and profit shifting (BEPS) and the value of intellectual proper-ty has propelled the two OECD projects on these key aspects of transfer pricing into the fore-front of the debate about the tax treatment of intra-group transactions.

Over the next two days, you will hear directly from the OECD about the development of theBEPS project and enhance your knowledge about other important transfer pricing issues,including how to navigate TP controversy, what you should be doing to manage your supplychain effectively and the impact the BRICS and other dynamic economies are having on yourtransfer pricing operations.,

Keeping up with transfer pricing developments has never been more important for taxpay-ers. Over the past year the concept of transfer pricing has never been more political or news-worthy. Taxpayers are being slammed for legitimate actions that have been deemed immoral.Company boards have been drawn in to discuss how to navigate this political minefield.

It has never been, therefore, more important for taxpayers and their advisers to take theopportunity to discuss how to cope with political pressures versus obligations to shareholderssimultaneously. We hope you find the opportunity to do so a key benefit of your attendance.

In this brochure you will find the biographies of each of the speakers that will feature overthe next two days.

International Tax Review is grateful to Deloitte, the conference’s main sponsor, who has con-tributed significantly to what will be a lively two days of debate.

We would also like to thank all our moderators and speakers for agreeing to take part andfor the time and effort they have committed to help make this event a success.

We look forward to meeting you all over the next two days at the different networkingopportunities on offer, including the cocktail reception and we hope to welcome you all againin 2014.

Best wishes,

Ralph Cunningham, Sophie AshleyManaging editor, International Tax Review Managing editor, TPWeekwww.itrpremium.com www.tpweek.com

| 1September 18-19, 2013 • Crowne Plaza Times Square, New York

Welcome letter | www.internationaltaxreview.com

Speaker contacts | www.internationaltaxreview.com

Helio AraujoBNP Paribas

Sophie AshleyInternational Tax Review

Claudie BouchardCirque du Soleil

Luiz Felipe Centeno FerrazMattos Filho

Sameer ChaudharyHewlett-Packard

Kerwin ChungDeloitte

Kenneth ClarkFenwick & West

David CordovaDeloitte

Ralph Cunningham International Tax Review

Napoleão DagneseOerlikon

Catherine DamelincourtAlstom

John DrewnoCaterpillar

David ErnickUSCIB

David ForstFenwick & West

Shanto GhoshDeloitte

John HenshallDeloitte

Cindy HustadDeloitte

Mohammed IqbalDeutsche Bank

Michael KeenInternational Monetary Fund

Matthew Koch Lexmark International

Inga KondrataiteNissan Europe

Eunice KuoDeloitte

Jean-Jacques LefebrveDeloitte

Don MaherThe Dow Chemical Company

Arin MitraDeloitte

Oscar MolinaMexican Tax Authority

Andrew NewmanDeloitte

Lionel NobreDell

Ken O’MahonyThe Kerry Group

Rob O'ConnorDeloitte

Robert PlunkettDeloitte

Keith ReamsDeloitte

Melvin RodriguezPVH

Pascal Saint-AmansOECD

Julia SceatsAIG

SP SinghDeloitte

Lynne SullivanBiogen

Will ThompsonBrown-Forman

Brian TullyThomson Reuters

John WellsDeloitte

Todd WolosoffDeloitte

Bill YohanaDeloitte

2 | September 18-19, 2013 • Crowne Plaza Times Square, New York

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Global Transfer Pricing Forum 2013

HELIO ARAUJO

LATAM Head of Tax BNP Paribas

Helio Araujo is the LATAM head of tax at BNP Paribas. He has a jurisdoctor degree (JD) from Universidade Federal de Minas Gerais –UFMG, a general MBA from Bernard M Baruch College (CUNY andan LLM in taxation from New York University. Helio is financial andcapital markets taxation professor at Fundação Getúlio Vargas.

Helio is a counsel at the Brazilian Administrative Chamber of TaxAppeals – 1st Section, in Brasilia, DF, judging corporate income tax cases. He was previously in the3rd Section judging mainly Brazilian Gross Income Contributions (PIS and COFINS) and import taxcases.

He is a a member of the Brazilian Bar Association – Sao Paulo Chapter.

CLAUDIE BOUCHARD

Director, Corporate Taxation, Planning and Transfer Pricing, Cirque du Soleil

Claudie Bouchard is the director of corporate taxation, planning andtransfer pricing at Cirque du Soleil. Since 2008, she has been in chargeof Cirque’s transfer pricing team and has helped the Cirque with taxaspects related to the presentation of touring and permanent Cirquedu Soleil’s shows around the world. She holds a master’s degree infiscal law and is a member of the CPA-CGA professionnal association.

Claudie started her career in an accounting firm and later oriented herself towards corporate taxa-tion while working with the Canadian tax authorities (Canada Revenue Agency). In 2008, she final-ly joined Cirque du Soleil. She has more than 17 years’ experience.

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SAMEER CHAUDHARY

Americas Transfer Pricing ManagerHewlett Packard

Sameer has more than 13 years’ experience in transfer pricing and is atransfer pricing manager at Hewlett-Packard. He is responsible for vari-ous transfer pricing matters including managing the company’s globaldocumentation efforts, developing and maintaining various transfer pric-ing policies and dealing with transfer pricing audits. Sameer also hasextensive experience on the operational aspects of transfer pricing and works closely with businessfinance, controllership, IT and other key functions across the company. Before joining Hewlett-Packard, Sameer was a senior manager with KPMG, spending 10 years in the New York, Toronto andSydney practices. He has advised both US and foreign-based multinational companies on varioustransfer pricing controversy, planning, global/local documentation and operational transfer pricingengagements.

LUIZ FELIPE CENTENO FERRAZ

PartnerMattos Filho, Veiga Filho, Marrey Jr e Quiroga Advogados

Luiz Felipe Centeno Ferraz performs tax-advantaged structuring andadvises clients generally about investments, public and private M&A, andcross-border transactions. His practice also includes transfer pricing mat-ters.

Luiz Felipe is a frequent speaker at international tax seminars and he haspublished numerous articles on Brazilian taxation in Brazil and abroad. He serves as a legal counselto the Federation of Industries of São Paulo (FIESP) and is vice-chairman of the international tax com-mittee of the American Bar Association’s (ABA) International Law section. He has been named byChambers Latin America, PLC Which Lawyer and Who’s Who Legal as a leading tax practitioner inBrazil. He holds a master of laws (LL M) degree in taxation from the Fredric G Levin College of Lawof the University of Florida, which he attended on a Fulbright Scholarship.

Biographies | www.internationaltaxreview.com

September 18-19, 2013 • Crowne Plaza Times Square, New York

KENNETH CLARK

Partner, Tax Fenwick & West

Kenneth Clark is a partner in the tax department of Fenwick & West andchairs its tax litigation group. The principal focus of his practice is complexfederal tax litigation and tax controversy work. He regularly practises in theUS Tax Court and has published a number of articles relating to tax contro-versies. Fenwick & West has worked on more than 70 federal tax litigations.

Ken has worked on numerous high profile tax controversy matters, for clients such as Xilinx; TheLimited; Limited Brands; Textron; Apple; Daimler; GM Trading; Dover Corporation and Adaptec.

With more than three decades of experience, Ken has also managed a variety of complex commercialdisputes in a number of foreign countries and more than 20 states. Litigation prevention and alterna-tive dispute resolution (ADR) also have been important parts of his practice. He has served asFenwick & West’s ADR coordinator, as an American Arbitration Association arbitrator and has beeninvolved in numerous mediations and arbitrations.

KERWIN CHUNG

PrincipalDeloitte

Kerwin Chung is a principal in Deloitte Tax’s Washington national tax officeand leader of the firm’s national advance pricing agreement (APA) and mutualagreement procedure (MAP) group. He has more than 16 years’ transfer pricingexperience, specialising in APAs, MAP, planning, examinations and customsmatters. He has served as the taxpayer’s lead negotiator for more than 80 APAsand has represented more than 100 taxpayers in the MAP process. His clientsinclude US and foreign multinationals in numerous industries, including apparel, automotive, chemicals,computers, construction equipment, consumer electronics, electronic components, food and beverage,industrial machinery, insurance, logistics, office products, pharmaceuticals, photography, professionalservices, and publishing.

Kerwin’s practice has involved complex transfer pricing issues, including negotiating a bilateral APA androllback for a pharmaceutical company that resulted in the withdrawal of a $100+ million IRS transferpricing adjustment and penalty assessment; negotiating a bilateral APA and rollback to eliminate doubletaxation resulting from post-year-end transfer pricing adjustments paid to a US subsidiary that were notdeductible in the foreign tax jurisdiction; and negotiating a bilateral APA in conjunction with a customsruling request to obtain both transfer pricing and customs valuation certainty.

He has co-written many publications, including ‘Seeking Efficiencies in the New IRS APA and MAPProgrammes’, International Tax Review (November 2011); ‘Competently Negotiating the US CompetentAuthority Process’, 59 Tax Executive No 3, p 257 (May/June 2007); and Transfer Pricing Rules andCompliance Handbook (CCH 2006). He has been recognised by inclusion in the Euromoney Legal MediaGroup’s Expert Guide to the World’s Leading Transfer Pricing Advisers since 2002. He is an active mem-ber of the ABA Tax Section Transfer Pricing Committee, having moderated a panel on transfer pricingissues in a down economy in 2009 and presented on a panel discussing the IRS APA program in 2011.


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RALPH CUNNINGHAM

Managing EditorInternational Tax Review

Ralph Cunningham became managing editor of International Tax Review,which covers cross-border corporate tax issues for multinational compa-nies, in November 2003.

Ralph and an editorial team of six are responsible for the content ofInternational Tax Review, which includes a magazine that comes out 10 times a year, websites(www.internationaltaxreview.com, www.tpweek.com and www.itrpremium.com), supplements andother products, such as awards and the annual World Tax and World Transfer Pricing directories.

He also hosts events on behalf of the publication such as the Global Transfer Pricing Forum, whichhas been running for more than 10 years; the Asia Tax Executives’ Forum and the India Tax Forum;and the annual European and Americas Tax Awards dinners and has moderated the successful seriesof web seminars the magazine has run since 2007.

DAVID CORDOVA

PartnerDeloitte

David Cordova is an international tax partner based in Seattle. He hasmore than 26 years of experience specialising in providing internationaltax services to multinational companies ranging from start-ups to Fortune100 companies. He has extensive cross-border tax experience as well as ininternational M&A, structuring foreign operations and negotiations withtax authorities. He is one of Deloitte’s global specialists in internationalaccounting for income tax. David also serves as a member of the firm’s business model optimisationleadership team and has many years of practical experience working with clients in intangibles-ori-ented industries such as technology and consumer businesses. Most recently, David has led ourclients and markets organisation for the Asia Pacific region.

David is a member of the American Institute of Certified Public Accountants. He is a graduate of theUniversity of Washington, where he holds a BA in accounting, as well as the Denver University grad-uate tax programme.



CATHERINE DAMELINCOURT

Vice President Coroporate TaxALSTOM

Catherine graduated from the Institut d’Etudes Politiques and DEA inBusiness Law. She has developed her career mainly in major french indus-trial groups:

Between 1978 and 1990 , she was international tax adviser for Alcatel, incharge of the negotiation and implementation of major Technology Transfer agreements in emergingmarkets.

From 1990 to 2000, she was international tax adviser and then group vice-president, tax, at Sanofiuntil the merger with Synthelabo.

In 2001, she became senior vice president, finances, tax for Lafarge, a group which is present in about80 countries, where she managed a team of 20 tax lawyers .

She joined the EDF group as group tax vice-president in 2008, closely participating in the acquisitionsof British Energy (UK ) and Constellation (US).

Since 2008 she has vice-president, corporate tax for Alstom.

NAPOLEÃO DAGNESE

Head of International Tax Oerlikon

Napoleão Dagnese studied law in Brazil (Unisinos, in São Leopoldo RS). InGermany he earned a masters in economics, a specialisation in tax law anda PhD focused on the Brazilian and German transfer pricing documentationrules (Ruhr University Bochum). These programmes were followed by aspecialisation in corporate finance (Swiss Banking Institute at the ZurichUniversity). He has several publications in leading European and SouthAmerican journals dealing with international taxation.

In Brazil Napoleão worked as a consultant to multinational enterprises and export-oriented compa-nies. During his doctorate he worked in the transfer pricing team of a Big 4 firm in Düsseldorf. Since2006 he has worked in Switzerland and is head of international tax of OC Oerlikon, a traditionalSwiss high-tech multinational with innovative industrial solutions for the efficient and clean produc-tion of food, clothing, transportation systems, infrastructure, energy and electronics. Oerlikon is pres-ent in 38 countries with 150 sites and more than 17,000 employees.


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DAVID ERNICK

SpokespersonUSCIB

David Ernick is a principal in the transfer pricing practice of the PwCWashington National Tax Services office and a spokesperson for USCouncil for International Business.

Before joining PwC, David was associate international tax counsel at theUS Treasury Department. While at Treasury from 2004 to 2013, his responsibilities included negoti-ating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislativematters. He also represented the US as a delegate to the OECD Working Party No 6 on TransferPricing, and chaired its special session on business restructurings. David was the principal staff attor-ney for transfer pricing matters at Treasury, and advised on every significant guidance project in thisarea released by Treasury and the OECD in the last nine years.

Before joining Treasury, David practised as a tax associate at Cravath Swaine & Moore in New Yorkand at Wilmer, Cutler & Pickering in Washington. He has clerked at the US Tax Court and the USCourt of Appeals for the Eleventh Circuit. He serves as an adjunct professor and teaches a course ontransfer pricing in the Graduate Tax Program at Georgetown University Law Center. He is also a co-author of the 2013 Practising Law Institute’s (PLI) Transfer Pricing Answer Book.

JOHN DREWNO

Transfer Pricing Manager Caterpillar

John Drewno began his tax career working as an economist with the nation-al office of the Internal Revenue Service in Washington, DC where he man-aged portions of the Corporate 1120 Program and provided technical supportto IRS field offices.

Since 1997, he has worked in several countries and held numerous seniormanagement and partnership positions with Big 4 and international tax consulting firms specialising inthe international tax and transfer pricing fields. Working with Fortune 100 multinational corporations,John’s international tax and transfer pricing specialty work focuses on international tax compliance, plan-ning, and controversy issues for multinational corporations. John has served as an expert witness in liti-gation environments, tax arbitration proceedings and foreign jurisdictional tax proceedings and has rep-resented clients interests by providing testimony on IRS and Treasurys proposed services/ intangiblesregulations in 2004 and 2006, proposed cost sharing regulations in 2005, proposed foreign based compa-ny sales income / contract manufacturing regulations in 2008, and proposed controlled group loss regu-lations in 2011. John provided testimony to the US House Ways and Means Committee on the issue ofpresent law and background related to possible income shifting and transfer pricing in 2010.

John has also advocated before the OECD on multiple International tax Issues including administrativeaspects of transfer pricing, safe harbours, timing issues and intangibles. He was an invited consultant tothe OECD Working Party No 6 on Transfer Pricing and Business Restructuring in 2009.

John is regularly cited in leading global tax and legal publications including CCH, BNA, Tax Notes, TaxAnalysts, Wolters Kluwer, Tax Notes International, TPWeek, Tax Core, the Daily Tax Report, the WeeklyReport, the Transfer Pricing International Journal and the International Tax Monitor.



SHANTO GHOSH

Senior Director, Transfer Pricing Deloitte

Shanto Ghosh is a transfer pricing partner with Deloitte India. He hasrecently relocated to the US and works in Boston. He has more than 12 years’transfer pricing experience, six of those years working in the US.

Shanto has advised clients in the life sciences, technology (including mediaand telecommunications), and automobile sectors. He has been actively involved in assisting clientswith their global transfer pricing policy and documentation and has implemented a number of large-scale global planning and supply chain restructuring projects. He also established and successfullyset up Deloitte’s global transfer pricing centre in India, which supports the global Deloitte networkin performing global documentation studies for multinational companies.

Shanto has been recognised in the Euromoney Legal Media Group’s Expert Guide to the World’sLeading Transfer Pricing Advisers. He is also a visiting lecturer at the IBFD and a member ofInternational Taxation magazine’s editorial board. He is a frequent speaker at international confer-ences across the globe and has published a number of high-profile articles.

In addition to his consulting experience, Shanto has been a teaching fellow at the Harvard Instituteof International Development and a lecturer in financial and development economics at theUniversity of California, Berkeley.

Shanto holds a PhD in economics from Boston University, a master of arts (Economics) from DelhiSchool of Economics and a Bachelor of Science from the University of Calcutta.

DAVID FORST

Partner & Chair, Tax Fenwick & West

David Forst is the practice group leader of the tax group of Fenwick & West.He is included in the Euromoney Legal Media Group’s Expert Guide to theWorld’s Leading Tax Advisers. He is also included in Law and BusinessResearch’s International Who’s Who of Corporate Tax Lawyers (2009, 2010,2011 and 2012). David was named one of the top tax advisers in the westernUS by International Tax Review, is listed in Chambers USA America’sLeading Lawyers for Business (2011-2012), and has been named a Northern California super lawyerin tax by San Francisco Magazine.

David’s practice focuses on international corporate and partnership taxation. He is a lecturer atStanford Law School on international taxation. He is an editor of and regular contributor to theJournal of Taxation, where his publications have included articles on international joint ventures,international tax aspects of M&A, the dual consolidated loss regulations and foreign currency issues.He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on inter-national issues. He is a frequent chair and speaker at tax conferences, including the NYU TaxInstitute, the Tax Executives Institute, and the IFA.

David graduated with an AB, cum laude, Phi Beta Kappa, from Princeton University’s WoodrowWilson School of Public and International Affairs, and received his JD, with distinction, fromStanford Law School.


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CINDY HUSTAD

Director, Tax Controversy ServicesDeloitte

Cindy Hustad is the tax controversy services competency leader for theUS West Region for Deloitte and represents corporate clients before theIRS. During her 14 year tenure at Deloitte, Cindy has successfully repre-sented many large and small clients, both at the examination and appealslevels, specialising in transfer pricing and international issues. Beforejoining Deloitte, Cindy was a special trial attorney with the IRS chief counsel’s office where she rep-resented the IRS in US. Tax Court in more than 50 litigated cases. During her period at the IRS, Cindyalso advised large-case agents, international examiners and appeals officers in some of the largestexaminations undertaken by the IRS, involving a wide range of complex international and domesticcorporate issues. Cindy also represented the government in litigating several large corporate tax andtransfer pricing cases, including DHL v Commissioner.

JOHN HENSHALL

Partner, Co-Global BMO Leader Deloitte

With more than 20 years of experience, John Henshall is global co-leaderof Deloitte’s Business Model Optimisation practice and also has a stronginterest in the transfer pricing of intangibles. These interests have led Johnto be invited to speak as a delegate at the OECD on the revision to thenotes to article 5 of the OECD model treaty, and the revision to ChapterVI of the transfer pricing guidelines. He features in the Euromoney LegalGroup’s 2011 Expert Guide to the World’s Leading Transfer Pricing Advisers.



MICHAEL KEEN

Deputy Director, Fiscal Affairs DepartmentInternational Monetary Fund

Michael Keen is deputy director of the fiscal affairs department of the IMF,where he was previously head of the tax policy and tax coordination divi-sions. Before joining the Fund, he was professor of economics at theUniversity of Essex and visiting professor at Kyoto University. He wasawarded the CESifo-IIPF Musgrave prize in 2010, delivered the 2012Chelliah lecture at the National Institute of Public Finance and Policy in Delhi, is honorary presidentof the International Institute of Public Finance (of which he was elected president from 2003 to 2006),and in 2008 was ranked the world’s leading author in public economics journals. He has led techni-cal assistance missions to nearly 30 countries on a wide range of issues in tax policy, and consultedfor the World Bank, European Commission and the private sector. He has served on the board of theNational Tax Association in the US, and on the editorial boards of American Economic Journal:Economic Policy, International Tax and Public Finance (of which he was joint founder), Journal ofPublic Economics, The Review of Economic Studies and many other journals. He is co-author ofbooks on The Modern VAT, the Taxation of Petroleum and Minerals, and Changing Customs. Recentpublications have also appeared in the American Economic Review, Economic Policy, the Journal ofPublic Economics, Journal of Development Economics and the National Tax Journal.

MOHAMMED IQBAL

Global Head of Transfer Pricing Deutsche Bank

Based in London, Mohammed manages the transfer pricing function ofDeutsche Bank with a global team located in major jurisdictions includingFrankfurt, London, New York and Hong Kong. Mohammed has more than16 years of experience in the field of transfer pricing. He joined DeutscheBank in 2006. He began specialising in financial services transfer pricing atBNP Paribas, moved to Merrill Lynch after four years, and for the followingsix years he was part of a small team managing transfer pricing matters for the organisation.Mohammed has considerable experience in developing solutions to a wide range of complex trans-fer pricing issues and in the practical design, implementation and defence of transfer pricing policies.Mohammed qualified as a chartered accountant with EY.


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INGA KONDRATAITE

Head of Transfer Pricing AMIE Nissan Europe

Inga Kondrataite is the head of transfer pricing for the AMIE region, cov-ering Africa, Middle East, India and Europe at Nissan, one of the world’slargest automotive multinationals. She is responsible for all transfer pric-ing aspects, including regional transfer pricing policy, compliance, trans-fer pricing audits, APA negotiations with the tax authorities across theregion and transfer-pricing-related support in various business projects. Before joining Nissan in thebeginning of 2011, she was a transfer pricing and international tax adviser at Deloitte.

MATTHEW KOCH

Head of Global Transfer Pricing Lexmark International

Matthew Koch is the head of global transfer pricing for LexmarkInternational and is responsible for the company’s worldwide transferpricing policy, as he oversees the development of the company’s world-wide strategy and compliance for transfer pricing. He is also heavilyinvolved with Lexmark’s international tax planning for a variety ofissues, including M&A, application of income tax treaties, and intangi-bles.

Matthew earned his bachelor’s degree in economics from the University of Virginia and his lawdegree from the University of Kentucky where he focused his studies on taxation. After law school,he went to work in public accounting where he obtained his certified public accountant’s licence andwas a member of the business tax advisory group at EY immediately before he joined Lexmark.



JEAN-JACQUES LEFBRVE

Partner Deloitte

Jean-Jacques Lefebvre, or JJ, as he is commonly known, is a partner in Deloitte’s global transfer pric-ing and tax controversy practice. Before joining Deloitte, he most recently served as the director gen-eral, International and Large Business Directorate (ILBD) of the Canada Revenue Agency (CRA). JJgained tremendous experience with the CRA’s compliance efforts and a deep understanding of itspolicies and procedures.

JJ began his career with the public service in 1975 as a general taxation officer for Revenue Canada.In 1980, he was appointed to the position of group head investigations and since then held progres-sively senior management positions including group head business audit, chief business audit andlarge files, chief audit review, chief specialty audits and regional adviser compliance programs. In1999, he joined the senior executive team as the assistant director of audit and was appointed thenational director for aggressive tax planning in 2005 and then, director general, ILBD, in 2007.

As the Director General, ILBD, JJ was responsible for providing policy and program direction to theCRA’s field auditors, and, as one of Canada’s delegated competent authorities, he was responsiblefor the administration of Canada’s income tax conventions. In his capacity as director general, JJ wasresponsible for a number of change initiatives within ILBD, such as: “One”, an effort to synchroniseCRA’s audit efforts in relation to large taxpayers; risk assessment for large files to improve the useand effectiveness of CRA’s audit resources; the introduction of workload mobility to complementrisk assessment efforts; and the implementation of an industry/sector-based approach that involvedthe development of centres of expertise to improve the CRA’s awareness and understanding ofCanada’s large taxpayers.

EUNICE KUO

Tax PartnerDeloitte

Eunice Kuo is a tax partner with Deloitte China. She is the national leader of the China/Hong Kongtransfer pricing group in charge of transfer pricing, business model optimisation, and tax-structur-ing services. Kuo has 26 years of experience in providing cross-border tax services. Before joiningDeloitte China in 2010, she was the tax practice leader and led transfer pricing and international taxservices for Deloitte Taiwan.


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ARIN MITRA

Principal, US Intangibles Leader Deloitte

Arindam Mitra is a principal and a senior economist in the transfer pricingpractice of Deloitte Tax and leads the transfer pricing team in its Washington,DC office. Before relocating to the US in 2004, he co-led Deloitte’s Tokyotransfer pricing practice (2001 – 2004). He also served in Deloitte’s Sydney (aslead economist; 1998 – 2000), Los Angeles, Chicago and Washington, DCoffices over the last 14 years.

Arin is primarily engaged in economic and financial analysis of transactions between related entities of amultinational enterprise for the determination of arm’s-length prices, in valuation of intangible propertyand in the measurement and benchmarking of risk-return trade-offs. He specialises in dealing with taxauthorities on transfer pricing issues, including audits, competent authority negotiations and APAs. Hehas developed and negotiated pricing methodologies for more than thirty APAs, mostly bilateral, involv-ing the US, Japan, Australia, Canada and China. He has been recognised in the Euromoney Legal MediaGroup’s Expert Guides series as well as by International Tax Review as a leading transfer pricing adviserin the US. He has advised companies across a wide spectrum of industries including pharmaceutical andmedical equipment, automobile, technology, and branded consumer products in planning and docu-menting their transfer prices. He has successfully defended several clients in audits conducted by the taxauthorities and has worked with attorneys from several leading US law firms.

Arin also advises clients on potential effects of proposed changes to tax legislation and on treasury riskmanagement matters. While in Australia, he was an adjunct faculty member of the Australian GraduateSchool of Management, teaching corporate finance and economics to MBA students and a member of theNational Tax Liaison Group (on Transfer Pricing) of the Australian Tax Office.

DON MAHER

Director of Tax Planning Dow Chemical Company

Donald Maher is senior tax counsel at The Dow Chemical Company(Dow) in Midland, Michigan. Don’s experience principally relates tointernational transactions, cross-border acquisition and disposition plan-ning, and general tax rate reduction planning. Before joining Dow in 2007,Don worked at Koch Industries (Koch) where he served as an attorney-adviser to several Koch businesses. Further, before joining Koch, Donspent several years in public accounting working for KPMG and Deloitte and focused on the designand implementation of income shifting strategies, including the design of transactions and legalstructure for large US multinational technology enterprises. Don is originally from Phoenix, Arizonaand attended college at Creighton University. After college, he received an MBA from Thunderbird,a JD from the University of Pacific, and an LLM in Taxation from Georgetown University. He isadmitted to practise law in Michigan.



ANDREW NEWMAN

PartnerDeloitte Tax

Andrew Newman is a tax partner specialising in international tax matters formultinational companies (MNCs). With more than 33 years of experience, heserves clients in a variety of industries, including manufacturing, services, spe-cialty chemicals, fast-moving consumer goods, food processing and distributionand franchising.

Andrew is the co-global leader of Deloitte’s Business Model Optimisation service offering, which focuseson creating value though business transformation. In this role, he is heavily involved in working withMNCs to optimise their supply chain and operating model, and the tax benefits that can flow from suchbusiness transformations. His work has included the design and implementation of principal and intel-lectual property company structures in Europe and Asia.

Andrew has performed numerous global strategic tax reviews for MNCs to focus on reducing theirworldwide effective tax rate. In addition, he has been instrumental in pioneering a new approach to man-aging the effective tax rate of a global company while optimising its utilisation and repatriation of offshorecash. He has successfully implemented this Global ST2EPS methodology for many US MNCs. Andrewhas recently been recognised by his clients and peers as a leading tax practitioner in the international taxarea in the Global Best of the Best 2012 Guide and the Best of the Best USA 2012 Guide published by theEuromoney Legal Media Group. Andrew has published several articles on international tax matters inmagazines such as International Tax Review, The Tax Executive, Investment USA, and The InternationalTax Management Journal. He is a co-author of BNA’s Portfolio on the Allocation and Apportionment ofDeductions. He has spoken on international tax matters to various tax groups, including the Chicago TaxClub, the Tax Executives Institute, CITE (Council for International Tax Education), IFA and the NationalChamber Foundation.

OSCAR MOLINA CHIE

Head of the LB&I Division, Mexican Tax Administration Service

In 2013, Oscar Molina was appointed general administrator for large taxpay-ers (that is, head of the Large Business & International Division) within theMexican Tax Administration Service (SAT). He was deputy tax attorney gen-eral within the Ministry of Finance and Public Credit (2005-2013) and cen-tral administrator for large taxpayers litigation (that is, head of department)at SAT (2001-2005). Previously, Oscar practised law at several accountingand law firms. He received his law degree from Universidad Iberoamericana (1990) and his LLM ininternational and commercial law from the University of Kent at Canterbury, UK (1996). Oscar is amember of the Mexican chapter of the IFA.


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KEN O’MAHONY

Global Head of TaxKerry Group

Ken O’Mahony has been the global head of tax for the Kerry Group, a world leader in food ingredi-ents and flavours and a leading supplier of branded foods, since 2007.

With sales of €5.8 billion ($7.8 billion), the Kerry Group operates in 44 countries, services customersin more than 140 countries and is listed on the Dublin and London stock exchanges.

As the group head of tax, Ken has specific responsibility for:

• Management of the group effective tax rate• Management of the group’s tax teams in Ireland, UK, US, Malaysia and Mexico• International tax strategy• International transfer pricing• International M&A structuring

Ken is a chartered accountant, who has previously worked in consultancy and held senior financeroles at multinational companies in North America and Europe.

LIONEL NOBRE

Director, Latin America Tax Dell

Lionel Nobre has been Latin America tax director for Dell since 2006where he manages a team of more than 20 professionals and covers 14jurisdictions in the region. His main responsibilities include tax planning,tax compliance and tax controversy/litigation. His prior career includedworking for major international accounting and law firms, holding rolessuch as the director for the Latin American consulting services practice ofBDO Seidman and the director of the Brazilian business advisory services practice of GrantThornton.

Lionel is a frequent speaker at international tax conferences for several years in Brazil, the US,Argentina & Mexico and has published several articles on Latin American taxation as well being theauthor of the BNA Portfolio on Transfer Pricing in Brazil. He is a licensed attorney in Brazil, with alaw degree from the Pontifical University of São Paulo, an LLM in international law from thePontifical University of São Paulo; an LLM in comparative law from the University of Miami. He isalso a certified financial planner.



ROBERT PLUNKETT

Principal, Global & US Financial Service Transfer Leader Deloitte

Robert Plunkett is a principal in the New York office of Deloitte Tax, and theleader of Deloitte Tax’s financial services transfer pricing group. He hasserved some of the firm’s largest clients, including banks, investment banks,insurance companies, and investment advisers.

Robert’s banking projects have involved income and expense allocation among branches for activi-ties ranging from global trading to provision of ancillary/support services. His investment bankingexperience includes analysis of global trading of derivatives, M&A activity, and loan syndication. Inglobal trading transactions, Robert has helped to price the assumption of market risk, the assump-tion of credit risk, the performance of trading functions and the provision of sales/marketing servic-es. He has assisted insurance companies in pricing the transfer of risk among entities, and hasworked on a number of investment advisory projects, including the pricing of advisory functions,sub-advisory functions, custody functions and brokerage functions.

He devotes a considerable amount of time to the pricing of intercompany lending, the provision ofguarantees, and to transactions that transfer credit risk from one legal entity to another.

ROB O’CONNOR

Leader, Transfer Pricing & Competent Authority GroupDeloitte

Rob O’Connor is a Deloitte Canada tax partner based in Toronto. He has held a number of leadershiproles, including having led the transfer pricing Canadian practice for 15 years. He has more 25 yearsof public accounting experience with Deloitte, providing transfer pricing and corporate income taxplanning services to some of Canada’s largest corporations that are members of multinational corpo-rate groups. Rob is a member of the global transfer pricing leadership executive group.


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MELVIN RODRIGUEZ

Global Tax Director PVH

Melvin Rodriguez is tax director at PVH, one of the largest global appar-el companies. He has more than 20 years of experience as a transfer pric-ing and business valuation consultant. A large part of his consulting expe-rience was spent outside the US both in Mexico City and Amsterdam. Heleft the consulting life to join the Interpublic Group (IPG) of companies,the third largest global marketing communications company. At IPG he focused on the economics ofintercompany services, new media and the valuation and transfer pricing of marketing intangibles.At PVH, he is focused on the transfer pricing implications of post-merger integration, the implemen-tation of a globally integrated supply chain and the transfer pricing of complex intangibles in theapparel industry. His research is focused on the valuation of intangible property with an emphasison marketing and supply chain related intangible property. He is a graduate of the University ofChicago Graduate School of Business where he focused on industrial economics and marketing. Healso has graduate degrees in philosophy and ancient languages.

KEITH REAMS

Global and US Transfer Pricing Leader for Clients and MarketsDeloitte

Keith Reams is the US and global leader for clients and markets for Deloitte’sglobal transfer pricing services practice. He has advised clients around theglobe on intercompany pricing transactions with respect to income tax regu-lations in Argentina, Australia, Belgium, Brazil, Canada, Chile, China,Columbia, Czech Republic, Denmark, France, Germany, India, Ireland, Israel,Italy, Japan, Korea, Luxembourg, Malaysia, Mexico, the Netherlands,Norway, Peru, Poland, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, the UK and the US.He has assisted numerous multinational companies with international valuation and economic consult-ing services involving M&A activity, international tax planning, and restructuring and reorganisation ofinternational operations. Keith is on the global tax management team for Deloitte’s technology, media andtelecommunications practice and is a leader in the area of transfer pricing for newly emerging industries,such as electronic commerce and cloud computing, where he has extensive experience around the worldin helping clients extend their business models into new territories.

Keith has testified as a qualified expert in numerous valuation and transfer pricing disputes, includingthe cases of Nestlé Holdings Inc v Commissioner; DHL Corp v Commissioner; and United Parcel Serviceof America, Inc v Commissioner. In addition, he is one of only three economists in the US approved bythe New York State Department of Taxation and Finance to provide transfer pricing expertise and testi-mony in cases involving cross-border transactions within commonly controlled affiliated groups. He hasalso helped many clients to successfully resolve valuation and transfer pricing disputes before they reachtrial.

Keith completed course requirements for a PhD in nternational finance from New York University. Heholds a master of arts in economics from California State University Sacramento and a BS degree in chem-ical engineering from Stanford University.



JULIA SCEATS

Head of Global Trasnfer PricingAIG

Julia Sceats is global head of transfer pricing for AIG, a leading internation-al insurance organisation serving commercial, institutional, and individualcustomers throughout the world. Julia and her team are responsible for alltransfer pricing matters as they relate to the AIG organisation includingcompliance, documentation, implementation, policy setting and strategy.

Julia qualified as a chartered tax advisor with KPMG in 1998, subsequently moving into a transferpricing role with the firm in 2001. She joined AIG in 2008.

PASCAL SAINT-AMANS

Director, Centre for Tax Policy & AdministrationOECD

Pascal Saint-Amans took on his duties as director of the Center for TaxPolicy and Administration (CTPA) at the OECD on February 1 2012. AFrench national, he joined the OECD in September 2007 as head of theInternational Cooperation and Tax Competition Division in the CTPA. Heplayed a key role in the advancement of the OECD tax transparency agendain the context of the G20. In October 2009 he was appointed head of theGlobal Forum Division, created to service the Global Forum on Transparency and Exchange ofInformation for Tax Purposes, a programme with the participation of more than 100 countries.

Pascal graduated from the National School of Administration (ENA) in 1996, and was an official inthe French Ministry for Finance for nearly a decade. He held various positions within the Treasury,including heading the supervision of the EU work on direct taxes and overseeing legislation and pol-icy on wealth tax and mergers and spin-offs. He was also the head of tax treaty negotiations andmutual agreement procedures. In this capacity, he participated in the OECD Working Party No 1 ofthe Committee on Fiscal Affairs as the delegate for France before being elected chairman of WP1 in2005. He was also a member of the UN Group of Experts on International Co-operation in TaxMatters, becoming a rapporteur in 2006. Before leaving government service, he was deputy directorin charge of litigation at the Direction Générale des Impôts, the French tax administration.

Pascal also served as financial director of the Energy Regulation Committee between 1999 and 2002and was responsible for the introduction of new electricity tariffs.

Having earned a degree in history, Pascal also received a degree from the Institut d’études politiquesof Paris.


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LYNNE SULLIVAN

Vice President of TaxBiogen Idec

Lynne Sullivan is the vice president of tax of Biogen Idec Inc, a globalbiotech company located in Cambridge, MA. Before joining Biogen Idec,Lynne was the vice president of tax in North America for Merck KGaAand the vice president of tax for Serono Inc since 2000. Lynne was a taxpartner in Andersen’s Boston office before joining Serono, where she ledthe North East Region’s tax consulting practice for the firm. She has a BS in accounting from SuffolkUniversity and a MS in taxation from Bentley College. She has served as the co-chair of BIO’s financeand tax committee since 2007.

SP SINGH

Senior Director, Transfer Pricing Deloitte

SP Singh (SP, as he is known), advises multinational companies (MNCs) oninternational and domestic transfer pricing, encompassing documentation,planning, and controversy defence. SP is the chief negotiator for APAs andMAPs. He provides services to major multinational clients in a wide range ofindustries, including sourcing of apparel, software development, IT and ITeS,pharmaceutical, cosmetics, chemicals and energy. His clients are from variouscountries, including the US, the UK, Japan, Australia and France, apart from Indian multinationals.

Before joining Deloitte SP was with the Indian Revenue Service for more than two decades, functioningat various positions. Apart from others, he was posted as director of income tax (international taxation)and commissioner of income tax (appeals). He participated in the negotiation of tax treaties with morethan 30 countries and took part in MAPs. He has represented India in several international conferencesand presented papers. He was a member of the Expert Group on Transfer Pricing constituted by theMinistry of Finance for drafting the transfer pricing regulations. He represented the Income TaxDepartment before the Authority for Advance Rulings in several cases.

SP has an M Sc in fiscal studies from Bath University, in the UK, and has a masters in physics from India.He is a member of the Bar Council of the Income Tax Appellate Tribunal and is a regular faculty with theNational Academy of Direct Taxes (apex training institute for the Indian Revenue Service), the Institute ofChartered Accountants of India, IFA and the Indian Institute of Management, Lucknnow.

SP has co-written several white papers on TP related matters such as APAs and safe harbours and twobooks on transfer pricing. He regularly contributes to international and national journals on taxation.



BRIAN TULLY

Vice President & Head, ONESOURCE Transfer Pricing Thomson Reuters

As vice president and head of ONESOURCE Transfer Pricing worldwide,Brian Tully is responsible for advancing the strategic vision of the transferpricing software and service business within Thomson Reuters. Brian hasmore than 13 years of tax and accounting experience and has led teamsacross many functional areas. Previously, Brian served as vice president ofoperations for the global tax technology business segment of Thomson Reuters where he was instru-mental in numerous Fortune 500 implementations of TaxStream, helping to fully automate theirannual tax processes.

In 2002, Brian co-founded TaxStream which was acquired by Thomson Reuters in 2005. BeforeTaxStream, he worked as an investment banker for Lehman Brothers and Gleacher Natwest. Brianholds a BA. from Sienna College in New York. Brian is a frequent speaker at transfer pricing confer-ences and seminars in the US and globally.

WILL THOMPSON

Director of Transfer Pricing Brown-Forman

Will Thompson is the director of transfer pricing for Brown-Forman wherehe focuses on global supply chain related transfer pricing and tax issues.Before joining B-F, Will spent more than 10 years working in public account-ing, consulting on intangibles planning, value chain rationalisation, andtransfer pricing dispute resolution. His clients included global multination-als in the consumer products, technology, and pharmaceutical industries.Will is admitted to the Illinois bar and has earned degrees from Northwestern (LLM in tax), NotreDame (JD) and the University of Louisville (economics). Will is a frequent speaker at continuing edu-cation conferences and trade meetings.


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TODD WOLOSOFF

US & Global Managing Tax Partner Deloitte

Todd Wolosoff is the US and global managing tax partner for Deloitte’s trans-fer pricing practice. He has been a tax partner in the New York City office ofDeloitte for the last 25 years. He has extensive experience representing multi-national companies in a wide variety of transfer pricing matters.

Todd was the founding partner of the Northeast Transfer Pricing Group in 1990. He was a founding mem-ber of the National Transfer Pricing Leadership Group and has been in a leadership role for Deloitte in thetransfer pricing area for more than 20 years.

Todd has provided transfer pricing advice to many of the world’s largest multinationals. He has conduct-ed transfer pricing planning and documentation studies for both inbound and outbound taxpayers in vir-tually all industries, with a particular focus on consumer products, life sciences and pharmaceuticals, elec-tronics, automobile and automotive parts, medical products, chemicals, cosmetics, trading companies,and financial services. Todd is one of Deloitte’s leading specialists in transfer pricing controversy, direct-ing audit teams that have negotiated successful settlements in more than 50 audit controversies. He hasbeen involved in a number of groundbreaking audit cases and has led many of the largest transfer pric-ing audit engagements conducted by the firm in the US. He has also participated in transfer pricing auditsin Canada, France, Italy, the UK and Japan. For the past decade, Todd has led Deloitte’s highly attendedannual webcast on strategic planning for transfer pricing controversy. Todd has been recognised everyyear by the Euromoney Legal Media Group as one of the world’s leading transfer pricing advisers sincethe guide’s inception in 1999. International Tax Review awarded Deloitte the North America TransferPricing Firm of the Year, as well as New York Transfer Pricing Firm of the Year in 2011 and 2012. Toddhas been recognised by Mondaq as one of the world’s leading tax attorneys.

JOHN WELLS

Mid-America LeaderDeloitte

John Wells is the Mid-America leader of Deloitte Tax’s US transfer pricingpractice. He is experienced in managing large projects involving quanti-tative analysis in the areas of transfer pricing, intangible valuation, labourreform, finance, fiscal policy and international and macro-modelling.

Before joining Deloitte, John was the lead economist for the global energyand natural resources sector of another Big 4 firm and an economic adviser to the Kuwait govern-ment. He also spent four years on the faculty of Auburn University, where he taught PhD-level cours-es in time-series analysis, macroeconomics and international finance.

John has numerous publications to his name, and refereed for the American Economic Review,Economic Inquiry and other journals. He was awarded a National Science Foundation grant for hiswork on the effects of political events on financial markets.



BILL YOHANA

Director Deloitte

Bill Yohana is a director with Deloitte Tax in New York, where he specialises in financial transactionstransfer pricing, financial services transfer pricing and valuation

Over the past 14 years, Bill has advised clients on transfer pricing, with a focus on financial servicestransfer pricing (as an adviser to commercial and investment banks, asset managers, finance compa-nies and insurers) and financial transactions transfer pricing across sectors (including the pricing ofrelated-party loans, credit guarantees, the development of global loan and guarantee pricing policiesand the evaluation of thin capitalisation issues).

Bill was a partner of Deloitte in Melbourne for two years between April 2010 and April 2012. Beforebeginning his career in transfer pricing, he worked in institutional investment management (US, non-US, and emerging market equities), in interest rate derivatives structuring and marketing, and at theFederal Reserve Board, where he had a payments system policy formulation role.


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Global Transfer Pricing Proactively addressing global tax planning and tax compliance

About DeloitteDeloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

Copyright © 2013 Deloitte Development LLC. All rights reserved.Member of Deloitte Touche Tohmatsu Limited

Multinational organizations are operating in an environment of unprecedented complexity. Rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide, have made transfer pricing a leading risk management issue for global businesses. Deloitte’s transfer pricing professionals apply in-depth knowledge and experience to help develop, refine and maintain an effective transfer pricing program. We understand the current focus of tax authorities, and we have the technical and practical experience and tools necessary to help you navigate the transfer pricing environment in the U.S. and globally.

Deloitte’s global transfer pricing practice specializes in15 industries, our services include:• Advance Pricing Agreement Inbound• Global Documentation• Controversy Inbound• Strategic Transfer Pricing Review• Controversy Outbound• U.S. & India Advance Pricing Agreement• Business Model Optimization (BMO) Intellectual

Property Migration and BMO Supply Chain

To learn how you can win in a changing world, visit www.deloitte.com/tax/transferpricing.

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