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Highlights from TP Minds Americas 2014:

Highlights from TP Minds International 2013:
TP Minds International 2013 Highlights

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Already Confirmed to Speak in 2015:

Already Confirmed to Speak in 2015:

Garry Stone Partner PwC

Gary Stone is a Partner in PwC's Chicago office, and has been with the firm since 1988 and formerly the Global leader of the PwC Transfer Pricing network. Dr. Stone has directed and performed numerous analyses of intercompany pricing and economic valuation issues for Fortune 500 size companies. In particular, Dr. Stone has performed projects in the automotive, banking, chemical, computer hardware and software, cosmetics, distribution, electrical controls and equipment, financial markets, food processing, heavy and industrial equipment, medical supplies, mining, pharmaceuticals, plastics, retailing, semiconductor and telecommunications industries. Prior to joining the firm, he was an independent consultant and Assistant Professor of Economics; has written numerous articles and has made numerous presentations around the globe regarding transfer pricing.

Mike Danilack Principal, Global Tax Controversy & Dispute Resolution PwC

Michael Danilack, former deputy commissioner (international), IRS Large Business and International Division, has joined PricewaterhouseCoopers LLP as a principal in the transfer pricing group of the firm's Washington National Tax Services practice in December 2014. Mike joined the IRS in 2010. During his time there, he oversaw a wide range of international tax matters, including ensuring consistent tax treatment of U.S. taxpayers on international issues, providing timely and effective implementation of tax treaty and tax information exchange, and advising the LB&I commissioner on international tax administration. He also served as U.S. competent authority, overseeing mutual agreement procedure provisions of tax treaties. Before joining the IRS in 2010, Mike was with Burt, Staples & Maner LLP. He also served at the IRS in the 1990s as associate chief counsel (international) and as an assistant to the IRS commissioner. He received his LLM and his JD from New York University School of Law.

David Varley Acting Director, Transfer Pricing Operations IRS

Mr. Varley is Acting Director of Transfer Pricing Operations (TPO) in the IRS Large Business and International (LB&I) Division.  In this role, Dave oversees the Transfer Pricing Practice (TPP), the Advance Pricing and Mutual Agreement (APMA) program, and the Income Shifting Issue Practice Network (IPN).  TPP employs specialists that consult on transfer pricing matters in the field.  APMA negotiates Advance Pricing Agreements (APAs) and enters into Mutual Agreements with foreign tax authorities. The Income Shifting IPN focuses on a wide range of controlled transactions that may facilitate income shifting by a U.S.-based enterprise to lower-tax environments. Mr. Varley serves as the IRS delegate to OECD Committee on Fiscal Affairs Working Party 1 and Working Party 10.  He also has extensive and broad experience within the IRS and its Office of Chief Counsel.  Prior to his current position, he was a staff attorney to the IRS Deputy Commissioner for Services and Enforcement, Senior Counsel in Branch 7 of the IRS Office of Associate Chief Counsel (International), and senior team leader in the IRS Advance Pricing Agreement Program.

Kenneth W. Wood Senior Advisor; Large Business & International IRS

Ken Wood is currently serving as a Senior Advisor to the Acting Director, Transfer Pricing Operations, where he advises examination teams and attorneys on transfer pricing and valuation matters. Prior to his current position, Ken served as Senior Manager in the IRS’s Advance Pricing and Mutual Agreement Program, with responsibility for treaty relationships with Mexico and Canada.  From August of 2014 to January of 2015, Ken `served as the Acting Director, Transfer Pricing Operations. Ken’s career began with the US government in 1981 as an attorney in the IRS Chief Counsel’s office, where he drafted regulations and other forms of guidance, including transfer pricing and foreign tax credit regulations.  In 1995 he joined Ernst & Young LLP’s National Tax Office in Washington, DC, providing advice to taxpayers on a wide range of cross-border tax issues, including international restructuring, anti-deferral regime analysis, foreign tax credit planning, and transfer pricing.

Michael Lennard Chief Intl. Tax Cooperation & Trade; FfDO UNITED NATIONS

Michael Lennard is Chief of International Tax Cooperation in the Financing for Development Office (FfDO) of the United Nations. This work has a particular focus on ensuring the fairness and workability of international tax norms, including achieving greater developing country input into those norms, and encouraging cooperation to improve tax systems and administrations, as a spur to sustained development. Previously Mr Lennard was a tax treaty adviser in the OECD Tax Treaty Secretariat in Paris for three years and prior to that he worked on tax treaty and other international tax matters at the Australian Tax Office. He had earlier worked in the Australian government’s Office of International Law. He has led Australian negotiating teams on trade, investment, environmental and tax treaty matters and has prepared argument for matters before the Australian High Court, the US Supreme Court and the WTO. His published work on treaty interpretation has been cited before WTO panels and before the WTO Appellate Body. Mr Lennard has degrees from the University of Tasmania, the Australian National University and Cambridge.

Mayra Lucas Transfer Pricing Advisor OECD

Mayra Lucas has been a transfer pricing advisor at the OECD since June 2008. Her work focuses mainly in the core programme of work on transfer pricing, being actively involved in the project on transfer pricing of intangibles and transfer pricing documentation; and the work with non-OECD economies, with a special focus on Latin American countries. Previously, she worked as a senior tax consultant for Deloitte, as a consultant for DG Taxation at the European Commission and as a tax and corporate lawyer at Cuatrecasas, Gonçalves Pereira. She holds an LLM in Taxation from New York University School of Law.

Carlos Perez-Gomez Director of Transfer Pricing Examinations SAT

Carlos Perez-Gomez is presently Director of Transfer Pricing Examinations in the Mexican Tax Administration Service with more than 10 years of experience in the Transfer Pricing area. He has participated as instructor in Transfer Pricing Forums organized by Public Accountants Organizations in Mexico and Latin America, in Transfer Pricing training courses to foreign governments (Inter American Center of Tax Administrations [CIAT]), as the Mexican Delegate in the Working Party 6 of the Committee on Fiscal Affairs of the OECD, and he has participated as a co-author of several books on Transfer Pricing issues published internationally.

George Georgiev Senior Director; Transfer Pricing & Economic Analyses SIEMENS CORPORATION

A Senior Director in charge of transfer pricing with Siemens Corporation, USA, Dr. Georgiev has 18 years of experience in the field. Before joining Siemens, he spent 10 years as a consultant with Big4 companies in the US and Europe assisting MNEs from 25+ industries with TP planning, documentation, APAs and audit defense. The projects that Dr. Georgiev has managed include transfer of tangible and intangible products, cost-sharing, financing and services rendered for the benefit of related parties. As Head of Transfer Pricing with Siemens Corporation, he has focused on IP issues and economic support to multiple APAs and MAPs. Dr. Georgiev provides transfer pricing training to Siemens employees globally. 

Brandon de la Houssaye Transfer Pricing Director WALMART

Brandon de la Houssaye is a transfer pricing director at Walmart Stores, Inc.  His responsibilities include all areas of the transfer pricing life cycle, both international and domestic, with particular focus on policy development and audit support.  Brandon was formerly with GE Healthcare where he held the same level of responsibilities, and prior to GE he held various transfer pricing consulting roles.  Brandon has an MBA from Fisher COB / Ohio State University.

Humberto Reboredo Global Head of Transfer Pricing CREDIT SUISSE

Humberto M. Reboredo is Director and Global Head of Transfer Pricing for Credit Suisse.  He manages a team of 10 professionals around the world advising and implementing transfer pricing policies for the bank.  Prior to his current role, Mr. Reboredo was a Tax Counsel for Credit Suisse advising on a broad variety of corporate and partnership taxation issues, including the taxation of financial products.  Mr. Reboredo is currently a member of the Executive Committee of the Committee of Banking Institutions on Taxation. Before joining Credit Suisse, Mr. Reboredo was a Vice President and Tax Counsel at Morgan Stanley and an Associate at Cravath, Swaine & Moore LLP.

Niraja Srinivasan Executive Director, Tax DELL

Niraja Srinivasan leads the Global Transfer Pricing organization at Dell.  Prior to Dell, she spent 8 years at GE in a number of business and corporate transfer pricing and valuation/M&A roles. Niraja is a PWC alumni and has over 15 years of experience as a transfer pricing economist.

Kathryn O'Brien Principal, Transfer Pricing PwC

Kathryn is a Principal is PwC’s Transfer Pricing group based in Washington DC. Prior to joining PwC in 2013, Kathryn was the Global Transfer Pricing Leader for GE, where she managed transfer pricing risks and opportunities, oversaw documentation and controversies, coordinated global strategy, and led a 50 strong team of transfer pricing professionals. During Kathryn’s time with the IRS she helped launch the Advance Pricing Agreement program and was awarded IRS's Attorney of the Year in 1994. In her 26 year career, Kathryn has established herself as a frequent speaker at high-profile international conferences and worked closely with the OECD on all aspects of transfer pricing, more recently their work on Base Erosion and Profit Shifting.

Michael Cartusciello Executive Director, Global Transfer Pricing JP MORGAN

Michael Cartusciello is an Executive Director and part of the Tax Planning and Analytics Group at JPMorgan Chase with a primary focus on Global Transfer Pricing for the Firm.  He has more than 25 years experience in the application of US international tax laws for US multinational financial services entities and has published several articles on derivatives taxation. He is currently an advisor to and a past chairman of the Committee of Banking Institutions on Taxation. He is also an active member of the USCIB and USIBC.

Esther Mok Head of Transfer Pricing TD BANK

Esther is the Head of Transfer Pricing at TD Bank Group. Esther is accountable for transfer pricing compliance, audit risk analysis and management, policy, training and tax planning strategy. Esther acts as primary liaison with tax authorities on transfer pricing issues, provides advice in product offers and deal structures, provides thought leadership in emerging issues, provides transfer pricing subject matter expertise, build and maintain strong relationships within and across finance and businesses of TD Bank Group. Prior to joining TD Bank Group in 2006, Esther worked at PricewaterhouseCoopers’ Transfer Pricing Group. Esther has a Bachelor of Arts Co-op Accounting degree from the University of Waterloo and a Bachelor of Law degree from Osgoode Hall, York University. 

Diane Gardner Chief Tax Officer KODAK ALARIS

Diane Gardner is Chief Tax Officer for Kodak Alaris, a UK based consumer products company. Kodak Alaris began operations in September 2013 when it divested from Eastman Kodak, with over $1B in revenue and operations in over 30 countries.  Her team is responsible for all worldwide tax operations, including tax planning, compliance and transfer pricing. Prior to joining Kodak Alaris, Ms. Gardner spent 8 years at Eastman Kodak Company in a variety of roles, including Director of Domestic Income Tax reporting, Finance Director for Intellectual Property Transactions Group, and Director of Legal & IP Finance.  Prior to working at Kodak, Ms. Gardner served as Manager, Corporate Tax at Genencor International, Inc., and began her career at Arthur Andersen LLP.  Ms. Gardner earned both her B.S. and M.B.A. in Accounting from the State University of New York at Buffalo.  

Randall Fox Transfer Pricing & APA Specialist WORLD BANK GROUP

Randall Fox provides technical assistance on transfer pricing and APA matters to World Bank Group member countries around the world.  He has developed and executed on-the-ground capacity building workshops on technical transfer pricing and APA matters in numerous countries.  He has also assisted with the drafting of transfer pricing guidelines and APA procedures, and is currently helping establish several APA programs around the world. Before joining the World Bank Group, Randall was an APMA team leader with the IRS who focused mainly on cases involving high-value intangibles.  He has resolved cases with numerous countries, and was responsible for coordinating all MAP and APA cases between the US and Switzerland.  He has also spent time in the private sector with both Duff & Phelps and Ernst & Young focusing on transfer pricing and APAs.

Josef Hajek SVP, Tax and Governmental Affairs TUPPERWARE BRANDS

Josef Hajek is the Sr. VP of Tax & Governmental Affairs at Tupperware Brands Corporation. Josef joined Tupperware in 1996 and is currently responsible for the worldwide tax and governmental affairs functions of the company. Prior to joining Tupperware, he was with Price Waterhouse in Chicago. Josef has extensive experience in international taxation, Transfer Pricing, global restructurings, bilateral Advanced Pricing Agreements, Competent Authority and Permanent Establishment disputes.  He received his undergraduate degree from DePaul University and MBA from Kellogg School of Management, Northwestern University in Chicago, IL. 

Adam Katz Partner PwC

Adam M. Katz is a partner in the national Transfer Pricing practice of PwC and serves as global leader of transfer pricing policy. Adam has more than 25 years of experience assisting US and foreign-based multinationals with corporate international tax planning and transfer pricing, including three years on assignment in London.  Adam continues to serve in a strategic leadership role in PwC's financial services transfer pricing practice, having served as global leader for over 10 years. Adam advises multinational companies, mainly in the financial sector, on transfer pricing, global structuring, joint ventures, and cross-border asset transfers and valuations. His experience in transfer pricing includes global tax planning; US and global core contemporaneous documentation; and global tax controversy and dispute resolution, such as representation before the IRS with respect to advance pricing agreements, competent authority negotiations, and federal income tax examinations.  Adam’s experience with multinational financial institutions spans all major areas of the industry's transfer pricing including global dealing, investment banking, other high value client services, technology and other support functions, treasury and lending/guarantee arrangements, and  asset management and alternative investments.

Sam Sim Transfer Pricing GEO Leader Asia-Pac & Japan IBM

Mr Sam T Y Sim is Transfer Pricing GEO Leader Asia-Pac & Japan for IBM. Before joining IBM he was Head of  Transfer Pricing  (East) for Standard Chartered Bank in Singapore, a U.K. global banking group with networks in over 70 countries with a focus on Asia, Africa and the Middle East. He led a team of professionals in Singapore and India covering tax transfer pricing globally for the institutional and commercial banking businesses of Standard Chartered across Corporate Finance, Global Markets (including FICC and Equities), Capital Markets & Syndications, Principal Finance and Transaction Banking. Prior to joining Standard Chartered Bank, Mr Sim was previously a tax attorney in New York and an Assistant Director at the Monetary Authority of Singapore. He has a B.A. and M.A. (Economics) from Cambridge University, an L.LM (Taxation) from New York University and is a qualified attorney of both the New York and Singapore Bars.

Michal Stepian Global Tax Controversy Manager STRYKER CORPORATION

In his career, Michal Stepien has led transfer pricing and international tax planning functions. In his current role he is leading the tax controversy function of Stryker Corporation, managing tax audits in US, Europe and Asia, where he leverages his prior experience to better serve his Company. A father of three, he has lived in six countries and visited twenty more. He thrives on new experiences: he’s currently learning to fly planes and play the piano.

Katherine Amos VP, TP Strategy EATON

Katherine Amos is the Vice President of Transfer Pricing Strategy at Eaton, an Irish-based multinational focused on power management products and services with sales to customers in over 175 countries.  Previously, she was the global head of transfer pricing for Tyco International, a Swiss-based multinational operating in a variety of markets.  Katherine also spent 17 years in transfer pricing consulting at PricewaterhouseCoopers LLP and Ernst & Young LLP working with companies in a variety of industries with transfer pricing planning, documentation, and controversy needs.

Luiz Felipe Centeno Partner MATTOS FILHO

Luiz Felipe Centeno Ferraz performs tax-advantaged structuring and advises clients generally in connection with investments, public and private M&A, and cross-border transactions. His practice also includes transfer pricing matters. Mr. Ferraz is a frequent speaker at international tax seminars and he has published numerous articles on Brazilian taxation in Brazil and abroad. He serves as a legal counsel to the Federation of Industries of São Paulo (FIESP) and is Vice-Chair of the International Tax Committee of the American Bar Association’s International Law section. He has been named by Chambers Latin America, PLC Which Lawyer,and Who’s Who Legal as a leading tax practitioner in Brazil. Mr. Ferraz holds a Master of Laws (LL.M.) in Taxation from the Fredric G. Levin College of Law of the University of Florida, which he attended on a Fulbright Scholarship.

Charlie Middleton SVP Tax OXBOW

Charles Middleton is a tax lawyer focusing on international transactions and reorganizations.  Currently SVP and Tax Counsel for Oxbow, a global trading company in West Palm Beach Florida, Mr. Middleton previously held senior tax positions at GE, Caterpillar and Walmart.  At Walmart, Mr. Middleton was VP for International Tax responsible for Walmart’s tax planning globally.  At Caterpillar, Mr. Middleton led the worldwide tax team at Caterpillar Financial.  At GE, Mr. Middleton led the tax teams at GE Asset Management, GE’s $200B asset management business and FGIC, GE Capital’s bond insurance company.  Prior to entering the corporate sector, Mr. Middleton was a tax associate at Paul Hastings and McKenna Long in Atlanta.  His academic background includes an LLM in Taxation from New York University, a JD from Alabama School of Law and the Chartered Financial Analyst designation.  He is admitted in Florida, Alabama, Georgia, England and Wales.  Mr. Middleton has experience in the taxation of US multinational corporations with emphasis on outbound global M&A transactions, transfer pricing and IRS audit defense.

Ognian Stoichkov Global Transfer Pricing Director PEPSICO

Ognian Stoichkov currently serves as global transfer pricing director for PepsiCo, Inc.  He has responsibility for the global transfer pricing policy and global strategic projects for the company.  Prior to joining PepsiCo, Ognian spent 14 years with Big 4 transfer pricing practices in Detroit, Short Hills, NJ and New York. He has a B.A. in Economics from Reed College, a M.A. in Economics and Ph.D. Candidacy in Economics from the University of Michigan, Ann Arbor.


John Megna is the VP – Tax for Toshiba America, Inc.  John has been with Toshiba for over 26 years, and while with Toshiba, has many years of experience in the Transfer Pricing area and also with Advance Pricing Agreements (APAs).  John’s group also performs Documentation Studies for many of the Toshiba companies and / or divisions that are not part of their APA.  John is also responsible for Toshiba’s  IRS audit defense in the U.S.  John has also worked for Casio, Inc. for 5 years in the same capacity as with Toshiba and before Toshiba, John worked in a medium size Public  Accounting firm in his home state of N.J.

Jim Huber Senior Director, Transfer Pricing TYCO

Jim Huber is a Senior Director, Transfer Pricing, at Tyco.  Prior to joining Tyco in June 2012, Jim was a transfer pricing managing director with PwC New York specializing in providing consulting services to a range of clients from large MNCs to small start-up companies across varied industries, including industrials, consumer goods, retail, and pharmaceuticals. Jim has experience in managing large global restructuring engagements, documentation studies and intangible property migration projects. Jim began his transfer pricing career with KPMG in 1997.   

Juan Carlos Ceballos Head of Transfer Pricing THERMO FISHER

Juan Carlos Ceballos heads up operational transfer pricing at Thermo Fisher’s Life Sciences Division. He is a transfer pricing specialist with more than 10 years of experience in big four accounting firms and as an in-house transfer pricing expert in the U.S. Canada and Mexico. Juan Carlos has the knowledge and skills to plan, implement and defend tax-efficient transfer pricing policies. He has a B.S. in Economics from Universidad Autonoma de Guadalajara and MBA from EGADE Business School.

David Ernick Principal PwC

David Ernick is a Principal in the Transfer Pricing Practice of PricewaterhouseCoopers’ (PwC) Washington National Tax Services office. Prior to joining PwC, David was Associate International Tax Counsel at the U.S. Treasury Department. While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters. He also represented the United States as a delegate to the Organization for Economic Cooperation and Development Working Party No. 6 on Transfer Pricing, and served as the Chair of its Special Session on Business Restructurings.

Scott Campbell Global TP Manager FMC TECHNOLOGIES

A graduate from the University of Arkansas School of Law in 1997, Scott is presently Global Transfer Pricing Manager for FMC Technologies Inc based in Houston, Texas. Scott previously worked for Celanese Corporation, a Fortune 500 MNE chemical company, which he joined in 2005.  Scott led the global transfer pricing practice at Celanese (USD $5billion annually in intercompany tangible product transactions) for intercompany transactions relating to tangible products, shared services, IP, royalties, intercompany loans, guarantees and cash pooling.

Fabrizio Lolliri European Director of Transfer Pricing HOGAN LOVELLS

Fabrizio joined Hogan Lovells in 2013, he has extensive industry experience which is coupled with well-grounded “Big 4” training and entrepreneurship. He has a background in science and engineering, which allowed him to make the transition to transfer pricing first as an economist at Deloitte and then KPMG. Fabrizio then became the Group Head of Transfer Pricing for FranceTelecom and Orange. Fabrizio featured in the Top 40 Under 40 in 2012 and is a published author of the TP books for 2013 and writes regularly for the Tax Journal. Fabrizio’s portfolio of clients includes Global 1000 and FTSE 100 multinationals.

Claire Walters Director, Transfer Pricing TYCO

Claire Walters is a Director with Tyco’s  Transfer Pricing team in Princeton, New Jersey.  Claire began her career with Tyco 13 years ago in international tax located in the UK.   Claire transferred  to Tyco’s US headquarters  in 2008 and now specializes in Transfer Pricing and related tax matters. Claire has extensive practical experience in audit defense, documentation studies, and intercompany services.  She currently spends most of her time designing, implementing, and  monitoring a number of supply chain transformation projects for Tyco’s US and international businesses. Claire is a chartered accountant and began her career with PricewaterhouseCoopers UK.

Fabian Alfonso Partner BASEFIRMA

Mr. Alfonso is a partner for BaseFirma’s International Transfer Pricing Group in Miami, Florida.  Mr. Alfonso has 12 years of experience in devising transfer pricing policy and implementing, documenting, and defending cross border transactions for multinational companies.  He has been involved with numerous transfer pricing projects for companies operating in various industries, including the insurance, energy, personal goods, and telecommunications, among others.  In addition, Mr. Alfonso has overseen numerous multi-country transfer pricing coordination projects for multi-nationals located throughout Latin America and North America.

Sergio Sevilla Tax Director TELEFONICA

Sergio Abrajan Sevilla is a CPA and MBA, with more than 25 years of professional experience in the field of corporate taxation in Mexico and internationally. Sergio is currently Tax Director of Telefonica in Mexico. He is member of the IFA and of Colegio de Contadores Publicos de Mexico. Sergio is a frequent speaker at prominet tax conferences both in Mexico and internationally.

Brian Tully VP & Head, ONSESOURCE Transfer Pricing THOMSON REUTERS

As Vice President and Head of ONESOURCE Transfer Pricing worldwide, Brian is responsible for advancing the strategic vision of the Transfer Pricing software and service business within Thomson Reuters. Brian has over 13 years of tax and accounting experience and has led teams across many functional areas. Previously, Brian served as VP of Operations for the Global Tax Technology business segment of Thomson Reuters where he was instrumental in numerous Fortune 500 implementations of TaxStream, helping to fully automate their annual tax processes. In 2002, Brian co-founded TaxStream which was acquired by Thomson Reuters in 2005. Prior to TaxStream, he worked as an investment banker for Lehman Brothers and Gleacher Natwest. Brian holds a B.A. from Sienna College in New York. Brian is a frequent speaker at transfer pricing conferences and seminars in the USA and globally.

Jill Weise Managing Director DUFF & PHELPS

Jill Weise joined Duff & Phelps in 2012 as a managing director leveraging more than 18 years of transfer pricing expertise. Jill is currently the Salem Office City Leader, where she leads the New England transfer pricing team. Throughout her career, she has worked with clients in New England and beyond to address an array of transfer pricing issues – including planning analyses, global studies, advance pricing agreements, controversy, litigation (including expert witness testimony), state transfer pricing, cost sharing, intangible asset migration, FIN 48 calculations, and documentation for penalty protection. Jill has extensive industry experience in such areas as high-tech, computer software, biotechnology, medical instrumentation, pharmaceuticals, industrial products, chemicals, food and beverage, retail, and automotive. Prior to joining Duff & Phelps, Jill was the leader of Ceteris’ Boston practice and was integral to building the practice to the success it is today.

Fernando Cruz Director, Transfer Pricing AMERICAN EXPRESS

Fernando is the Director of Transfer Pricing at American Express. Fernando has over 12 years of experience in transfer pricing planning, intangible property restructuring, intercompany financial transactions, global intercompany service fee structuring, royalty rate planning, advance pricing agreements, cost sharing arrangements, U.S. and foreign country documentation studies, and U.S. and foreign country transfer pricing audits. Prior to joining American Express, Fernando worked for PwC, Baker & McKenzie and Andersen.

David Swenson Global Leader;Tax Controversy & Dispute Resolution Network PwC

David is the Global Leader of PwC's Tax Controversy and Dispute Resolution Network. David works with multinational companies on international tax matters focused on corporate tax planning, structuring worldwide businesses, transfer pricing, mergers and acquisitions, and the management and resolution of domestic and global tax controversies. During David's years as an international tax partner at one of the world’s largest law firms, David served as Chair of the Washington, D.C. Tax Practice, Chair of the Tax Controversies and Litigation Practice, and Chair of the Transfer Pricing Practice. David is a member of the American Bar Association, the District of Columbia Bar, and has been admitted to practice before the U.S. Tax Court, the U.S. Court of Federal Claims, as well as numerous U.S. Federal Courts of Appeal, and the U.S. Supreme Court.

Napoleão Dagnese International Tax Director DMG MORI

Dr. Napoleão Dagnese is International Tax Director of DMG MORI Group, a leading provider of cutting machine tools and services. He is based in the Swiss global headquarters and in charge of international tax matters including transfer pricing planning, implementation and documentation in 145 locations in 34 countries.  He has several years working experience in industry and consultancy and was based in Brazil, Germany and Switzerland. He studied law in Brazil. In Germany he concluded a master in economics, a specialization in tax law and a Ph.D. in international tax law, followed by a post-graduation in corporate finance in Switzerland and a specialization in Swiss  taxation. He has several publications in leading European and South American journals dealing with international taxation.

Todd Miller Partner HOGAN LOVELLS US

Todd Miller is a member of Hogan Lovells’ tax practice group. His practice encompasses a broad range of matters with particular emphasis on tax controversies, transfer pricing, international tax planning and corporate acquisitions, dispositions and reorganizations. He also serves as Hogan Lovells’ tax matters partner. Todd’s tax controversy work involves representing domestic and international clients in tax audits, and appeals before the IRS, in mediation and in litigation. Todd’s practice before the Internal Revenue Service also involves such matters as ruling requests, requests for extensions of time to file elections, and closing agreements.
Todd’s transfer pricing practice includes counseling domestic and international clients with respect to the transfer of intangible property, cost sharing agreements and the pricing of goods and services. It also includes the successful resolution of a significant number of transfer pricing matters with IRS Appeals and the resolution of other matters through competent authority procedures. Todd’s international tax planning practice involves advising U.S. businesses on the most tax-efficient means of expanding their foreign operations and international businesses on establishing and expanding their operation in the United States. Todd is also active in advising both domestic and international clients concerning corporate acquisitions, dispositions and reorganizations, including spin-offs.

Clark Armitage Member CAPLIN & DRYSDALE

Clark Armitage joined Caplin & Drysdale as a Member in 2013.  Mr. Armitage advises multinational corporations on transfer pricing matters, from planning to cross-border dispute resolution.  He has a strong background interacting with tax authorities on advance pricing agreements and competent authority matters for corporations in a variety of industries.  Mr. Armitage served as Deputy Director in the IRS Advance Pricing Agreement Program and, on a detail, as the Tax Treaty Manager responsible for Canadian Competent Authority cases.

Andrew Spada Head of Global Tax CAMBREX CORPORATION

Andrew is head of global tax for Cambrex Corporation, an innovative multinational life sciences company. He is in charge of worldwide transfer pricing, as well as planning, compliance, and reporting. Andrew has lead several multinational restructurings and other initiatives involving transfers of intangibles and intercompany transactions for intellectual property, services, sales, management fees, and loans. Prior to Cambrex Andrew held senior tax positions at publicly traded and private companies, after starting his career at PwC.   


David Nickson Pricinpal PwC

David is a principal in PwC’s Global Transfer Pricing practice and leads the firm’s End to End TP Execution group which focuses on the practical implementation of policies within financial and IT systems, and the associated communication and accounting/tax process improvement issues. 
David is a commercial international tax professional with over 19 years' experience (12 as partner/principal). He has extensive large company planning and corporate compliance experience, with credentials in the areas of tax-efficient financing, M&A planning, and intellectual property/business structuring.  Since 2010 David has focused specifically on transfer pricing execution, and is a recognized thought leader in this emerging practice area.  He is a Chartered Accountant, Chartered Tax Adviser, and Enrolled Agent.

Richard Belmonte Director of Transfer Pricing ECOLAB

Richard Belmonte is the Director of Transfer Pricing for Ecolab Inc.  Ecolab Inc. is the global leader in water, hygiene and energy technologies and services that provide and protect clean water, safe food, abundant energy and healthy environments.  Richard has been spent the past 13 years of his career with Ecolab.   Prior to his role as the director of Transfer Pricing he worked in the International tax group.   He has extensive experience in cross-border transactions, cash repatriation strategies and tax compliance.  Richard holds a B.S. degree in Accounting from the University of Wisconsin - River Falls and a Masters in Business Taxation from the University of Minnesota - Carlson School of Business.

Ednaldo Silva Managing Director Royaltystat

Ednaldo Silva PhD, is the Founder of RoyaltyStat LLC. He is an economist specialising in transfer pricing controversy and the valuation of intangibles and has extensive experience with litigation support and as economic expert in cases involving
transfer pricing controversy and APA submissions. While serving as Chief Counsel, Internal Revenue Service, Ednaldo Silva served as a drafting member for the Section 482 (Transfer Pricing) Regulations and as the first economist in the APA Program. He was responsible for introducing the “Comparable [Operating] Profits” Method (CPM, TNMM under the OECD Guidelines), the “Best Method Rule,”
and the Arm’s Length “Range” under the Section 482 Regulations.

Graeme Wood Head of Global Transfer Pricing PROCTER & GAMBLE

Graeme Wood joined the Procter & Gamble Company in 1988 as UK tax manager after previously having worked at Deloitte Haskins & Sells. In 2006, Graeme became Director, Global Taxes – Transfer Pricing within the Geneva office, relocating to Cincinnati in 2008. Graeme has also been involved with providing guidance to the OECD on business restructuring issues, presenting to an OECD Roundtable in 2005 and becoming a member of the Business Advisory Group for a recent Business Restructuring project.

Matias Pedevilla Transfer Pricing Global Coordinated Documentation Leader PwC

Mr. Pedevilla is a Transfer Pricing Principal in the Miami office of PwC. Due to his extensive experience in global and regional documentation and planning projects, he has been named as the Global leader of PwC’s service offering Global Coordinated Documentation (“GCD”). In addition, he is the Transfer Pricing Latin America Coordinator in the US, leading the Transfer Pricing Latin America Business Center. Mr. Pedevilla has extensive experience in the coordination and management of global and regional planning, restructuring and documentation projects. He has been heavily involved in the management of transfer pricing audits in Argentina, Costa Rica, Mexico and the U.S. In addition, he assisted in developing PwC’s Transfer Pricing practices in Argentina, Chile, Colombia, Dominican Republic, Ecuador, Peru, Mexico, Uruguay and Venezuela.

Theo Elshof Managing Director QUANTERA GLOBAL

Theo is a Managing Director Quantera Global based in The Netherlands and has more than 20 years’ experience in international tax, transfer pricing and tax control frameworks. His experience includes active participation in competent authority APAs and Mutual Agreement Procedures, design, planning, implementation and defense of restructuring projects, transfer pricing controversy / audits, tax and transfer pricing control frameworks. Before joining Quantera Global Theo worked for a large global transfer pricing firm, was a Senior Director of the Transfer Pricing team of a Big 4 firm in the Netherlands and was head of the APA-team of the Dutch Tax Authorities (DTA).

Daniel Erasmus Adjunct Professor; International Tax Law THOMAS JEFFERSON SCHOOL OF LAW

Dr. Daniel N. Erasmus is an international tax attorney, adjunct Professor of International Tax Law at the Thomas Jefferson School of Law in San Diego, CA, and Professor of their African associated www.TheIITF.net, a US enrolled agent, a US Tax Court Practitioner, and recognized for his work in tax risk management (domestic and international tax of multi-national organizations), international tax, and transfer pricing in Africa.
During 2013 he was the tax attorney in winning and settling various major transfer pricing disputes in Malawi, Uganda and Rwanda for large multi-national corporations. The amounts in question were for approx. USD$120m. He is also currently advising on a TP disputes in Zimbabwe and Zambia.

Kriti Velji Principal Advisor, Transfer Pricing & International Audit Inland Revenue (New Zealand)

Kriti has  has been employed with the Inland Revenue Department for the last nineteen years in various positions within the Department including: Investigator, Team Leader (Investigations), Manager (Investigations) and she currently holds a position of a Principal Advisor Transfer Pricing. In her current role, Kriti is responsible for the negotiation of Advanced Pricing Agreements, providing technical transfer pricing analysis, providing support and training for Investigation staff and the resolution of complex transfer pricing disputes. Kriti is a Chartered Accountant and a member of the New Zealand Institute of Chartered Accountants.

Luis Carrillo Transfer Pricing Director BUREAU VAN DIJK

Luis Carrillo is a transfer pricing economist with over 8 years of consultingexperience, including Big Four firms, with focus on intangible property valuationsand global transfer pricing compliance. Mr. Carrillo is currently responsiblefor developing global software solutions for transfer pricing for corporate taxdepartments and practitioners. Mr. Carrillo holds a BA in Economics from theUniversity of California, Santa Cruz.

Jay Urquidi Manager, Global Transfer Pricing MARSH & MCLENNAN

Jay Urquidi is a Manager of Global Transfer Pricing at Marsh & McLennan Companies, a Fortune 500 professional services firm, where he oversees tax transfer pricing for major subsidiaries worldwide. An adjunct Lecturer at NYU’s School of Continuing & Professional Studies, Jay teaches Introductory and Intermediate Transfer Pricing. With over 10 years in his field, Jay has published extensively, including a chapter in the Transfer Pricing Manual and articles in the New School Economic Review and the Transfer Pricing International Journal. Jay holds a B.A. in economics from New York University, and a Master of Public Administration degree from the University of Pennsylvania.

Gregory Johnson Managing Director GLOBAL CAPITAL ADVISORS

Greg Johnson, Managing Director, joined Global Capital Advisors in 2013 following a 25-year career in Bank of America Capital Markets Group, including as head of International Debt Capital Markets.  His transactional experience includes both public and private issues and a number of market innovations.  During his career, Greg dealt with numerous credit rating and restructuring issues, developing a deep appreciation of all aspects of debt issuance.  He believes this “real world” experience uniquely qualifies him to assist issuers of intercompany debt.  He earned an MBA from the Wharton School and a BSEE from the University of Virginia.

Brooks Beaudoin Manager, Global Transfer Pricing DESCARTES SYSTEMS

Brooks Beaudoin is the Manager, Global Transfer Pricing at The Descartes Systems Group Inc., a Waterloo, Ontario-based multinational provider of logistics software solutions.  Prior to joining Descartes, Brooks worked for Ernst & Young LLP in the Minneapolis and Toronto offices, providing transfer pricing  services to clients operating in a wide variety of industries.  Brooks has an undergraduate degree in Aeronautical Studies from the University of North Dakota, and an MBA from the University of Minnesota.

Brad Rolph Canada National Practice Leader; Transfer Pricing GRANT THORNTON

For the past 20 years, Brad Rolph has helped multinational companies plan, implement and defend transfer pricing policies. Recognized as one of Canada’s leading transfer pricing advisers, Brad was the first economist hired by any accounting firm in Canada to practice transfer pricing exclusively. He has successfully defended transfer pricing polices under audit, at appeals and at competent authority. Brad also provides litigation support and expert witness reports to law firms representing clients with transfer pricing matters. In addition to leading Grant Thornton’s Transfer Pricing Practice in Canada and the Americas, Brad is the Tax Service Line Leader in Southern Ontario. 

Sergio Luis Pérez Cruz Partner PwC Mexico

Sergio Pérez is a Partner at PwC´s Tax Controversy and Dispute Resolution practice in Mexico. Before joining the firm, Sergio held a high level position at the Mexican SAT’s Large Taxpayers Administration. Over his 8+ years career at SAT, besides leading a large transfer pricing audit team, he also was in charge of the APA Program and conducted Competent Authority negotiations for Bilateral APA’s and Mutual Agreement Procedures with other tax administrations. His areas of expertise include tax policy, cross border transactions, operational restructures, transfer pricing, PE issues as well as settlement negotiations, audit management and tax conventions.

Albert Heber Head of Transfer Pricing CNH Industrial

Albert H. Heber is the Director and Group Leader of Global Transfer Pricing for CNH Industrial (Case New Holland, Inc. (“CNH”), Iveco, and Fiat Powertrain ("FPT"). As head of the Transfer Pricing Department, Heber has responsibility for the implementation, management and documentation of CNH Industrial's transfer pricing policies and processes worldwide covering the valuation and documentation of intercompany tangible and intangible product transfers, financial services, intellectual property, and support services. Heber joined CNHI in June, 2006 bringing with him almost 24 years of tax practice in Big 4 and with closely held and publicly held companies. Heber is an attorney and has special expertise in Transfer Pricing which includes intercompany pricing management, documentation, and tax controversy.

Carlos Perez-Gomez Director of Transfer Pricing Examinations SAT (Mexican Tax Administration Service)

Carlos Perez-Gomez is presently Director of Transfer Pricing Examinations in the Mexican Tax Administration Service with more than 10 years of experience in the Transfer Pricing area. He has participated as instructor in Transfer Pricing Forums organized by Public Accountants Organizations in Mexico and Latin America, in Transfer Pricing training courses to foreign governments (Inter American Center of Tax Administrations [CIAT]), as the Mexican Delegate in the Working Party 6 of the Committee on Fiscal Affairs of the OECD, and he has participated as a co-author of several books on Transfer Pricing issues published internationally.

*** This is a partial list only. Many other industry names to be confirmed soon for 2015! ***

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