Since 2021 when 140 countries agreed on a global tax deal, international tax policy discussions have concentrated intensely on Pillars One and Two, which focus on the reallocation of residual profits of the largest and most profitable Multinational Enterprises (MNEs) to market jurisdictions and a 15% global minimum tax, respectively.
USCIB’s annual International Tax Conference was no exception. Discussions on Pillars One and Two were the focus of the two-day tax conference, hosted alongside the OECD and Business at OECD (BIAC) on October 30-31 in Washington DC. Hundreds of industry leaders and practitioners including USCIB members, U.S. and foreign government tax officials and press gathered for the much-anticipated event, hosted by USCIB VP and International Tax Counsel Rick Minor.
Lily Batchelder, assistant secretary for tax policy at U.S. Department of Treasury, served as plenary speaker and provided a framework for the two-day conference and touched upon an important element—the multilateral work at the OECD in the tax policy space.
“Today, at the 16th annual Tax Conference of the USCIB, the question is not should the international tax system change,” said Batchelder. “We already know from close to 15 years of experience that the system has changed and returning to old rules is not a real tax solution. Instead, the question is how should the international tax system change in order to encourage global tax certainty and stability? In my view, our multilateral work at the OECD has been, and will continue to be, essential to finding answers to those questions.”
Batchelder’s comments were echoed by Michael Plowgian, deputy assistant secretary for international tax affairs at the U.S. Treasury Department, who spoke on the first panel, The International Tax Agenda. “The administration remains committed to implementing Pillars One and Two,” said Plowgian. “We believe it’s the best way to address the instability that we see in the international tax system.”
The second day kicked off with panels on Pillar Two, discussing the implementation of the global minimum tax and improving global tax coordination, particularly relating to rule co-ordination and dispute prevention and resolution.
Beyond Pillars One and Two, experts also discussed other pressing issues such as addressing increased global mobility of workers, carbon mitigation approaches, tax certainty beyond the Pillars and the rationalization of other base erosion and profit shifting (BEPS) measures.
The conference was sponsored by USCIB. Corporate sponsors included EY, PwC, Amazon, Caplin & Drysdale, General Mills, KPMG, Baker McKenzie and ExxonMobil.
Other featured speakers included:
- Alan McLean, Chair, BIAC Tax Committee and former Executive Vice President, Taxation and Controller, Shell International Limited, UK (retired)
- Achim Pross, Deputy Director, OECD CTPA
- Barbara Angus, Global Tax Policy Leader, Ernst & Young (EY)
- Bob Hamilton, Commissioner of the Canada Revenue Agency; Chair of the FTA
- Bob Stack, Managing Director, Washington National Tax, Deloitte Tax LLP
- Brett Weaver, Partner, KPMG
- Carolina Perez-Lopez, Vice President, Global Tax Planning and Tax Counsel, Johnson & Johnson
- Carlos Eduardo Protto, Director of International Tax Relations, Ministry of Treasury, Argentina
- Dani Rolfes, Partner in Charge, Washington National Tax, KPMG
- Daniel Smith, Director, International Tax Planning & Policy, Alphabet
- Hannah Hawkins, Principal, Washington National Tax, KPMG
- Isaac Wood, Attorney-Advisor, Office of Tax Policy, U.S. Treasury
- Jason Weinstein, Vice President, Tax, North America, Amazon
- John Peterson, Acting Head of Division ICA, OECD CTPA
- John Stowell, USCIB Tax Committee Chair, Head of Global Tax and International Financial Reporting, The Walt Disney Company
- Josh Ruland, Principal, EY
- Kevin Nichols, Head of Tax ESG, Tax Communications, and Tax Policy, Uber
- Kyle Meng, Senior Economist, White House Council of Economic Advisers
- Liz Stevens, Member, Caplin & Drysdale
- Manal Corwin, Director, OECD CTPA
- María José Garde, Director General of Taxation, Ministry of Finance, Spain
- Mark Harris, Vice President and General Tax Counsel, The Coca-Cola Company
- Mark Martin, Principal, Washington National Tax, KPMG
- Marlene Nembhard-Parker, Co-Chair of the Inclusive Framework; Deputy Commissioner General, Legal Support Services – Tax Administration Jamaica
- Marco Iuvinale, Director of European and International Tax Affairs, Italian Ministry of Economy and Finance
- Mary Jones, Director, Benefits Taxation, Microsoft
- Mike Williams, Director of Corporate Tax, HM Treasury
- Nate Carden, Partner, Skadden
- Nick Schulz, Director of Stakeholder Engagement and Senior Policy Advisor, ExxonMobil
- Nicole Welch, Director, Treaty and Transfer Pricing Operations, LB&I, IRS
- Pat Brown, Principal, Washington National Tax, PwC
- Peter Blessing, Associate Chief Counsel (International) at the Internal Revenue Service
- Rafic Barrage, Partner, Baker & McKenzie
- Rick Minor, VP & International Tax Counsel, USCIB
- Robert Cusmano, Senior Director, Global Tax Policy, Procter & Gamble
- Silke Bruns, Director for International Taxes, Federal Ministry of Finance, Germany
- Thomas Bettge, Senior Manager, Washington National Tax, KPMG
- Tobias Appl, Partner, EY
- Tom Roesser, Tax Policy Counsel, Microsoft
- Tracee Fultz, Global Transfer Pricing Leader, EY
- Whitney Baird, President & CEO, USCIB
- Will Morris, Global Tax Policy Leader, PwC
- Yah Fang Chiam, Deputy Commissioner, Business Group, Inland Revenue Authority of Singapore
The 17th annual OECD USCIB International Tax Conference will be held on June 24-25, 2024 in Washington DC.