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Introduction to International Corporate Taxation

Johann Muller

Johann has worked in international tax since 1989. He worked as a tax lawyer in Amsterdam, London and New York on holding structures, conduit structures, structured finance and hybrids before becoming deputy head of tax for the world’s largest shipping company (Mærsk). There, Johann co-ordinated reorganisations in 100 countries, and did tax advocacy at the EU, the OECD and the UN. He also has experience in taxation of the offshore service industry. Most recently, Johann worked for the Danish competent authority on transfer pricing and presented Denmark as a WP6 delegate at the OECD.

He is a regular speaker at international tax conferences, presents videos on his Youtube channel, TaxPics, and regularly blogs on LinkedIn and the “Kluwertaxblog”, where he is a co-editor. Johann published “The Netherlands in International Tax Planning” with the IBFD in 2008 and self-published an e-book on Amazon, “A practical summary of the OECD’s 2010 Transfer Pricing Guidelines” (updated as at 1 January 2016). He is currently working on a book for Kluwerlaw on the allocation of profits to permanent establishments.

 

Introduction to US International Corporate Taxation

In-depth US International Corporate Taxation

Enrolled Agent

Narelle MacKenzie

Narelle seeks to understand the business operations and drivers to ensure that the global tax planning and compliance works in synergy with the business, and maximises the returns to shareholders, whilst ensuring such tax planning is done to the highest ethical standards.
She has worked in both public accounting and industry for employers such as Goodrich Corporation (a Fortune 500 company that was acquired by United Technologies), PricewaterhouseCoopers LLP, and Toyota Australia. Her business experience has covered diverse industries and activities, including supply chain activities and initiatives, identification and implementation of new manufacturing facilities, establishing representative offices, secondment arrangements, customer sales and support initiatives and general cross-border issues.

Narelle has advised on cross-border activities in many and diverse countries and works with tax advisors in those countries to identify optimal, strategic tax solutions for her clients. Some of the various countries experiences include: US (federal and state), Mexico, Brazil, Singapore, China, Scotland, India, Turkey, Japan, Germany, South Korea, Netherlands, Canada, Luxembourg, Chile, Sweden, Norway, Russia, Australia, UK and France.

As well as lecturing at SDSU, she is a highly sought after speaker, course instructor and guest lecturer and has presented at many and diverse conferences including CalCPA, the ABA, CITE, AWSA and PwC.

She is a Past President of CalCPA (San Diego chapter), and currently serves on the Audit Committee for St James by the Sea, La Jolla.

Narelle is an Australian CPA and a Californian CPA.

Transfer Pricing in Practice

Ken Almand

Ken advises on all aspects of transfer pricing including planning, assurance and compliance issues, working with multinational groups to develop and implement effective strategies that are aligned with their business and tax policies. With over 15 years’ experience across a wide range of transfer pricing matters he specialises in assisting clients with assurance issues, tax authority disputes, business restructuring, and thin capitalisation.

Ken is a partner and head of transfer pricing at RSM UK, formerly Baker Tilly. He previously headed Mazars’ transfer pricing team, who he joined from Ernst & Young, Formerly he was an International Tax Specialist working on transfer pricing at HM Revenue and Customs’ International Division where he advised on transfer pricing policy and led on complex enquiries and litigation issues. He regularly contributes articles to tax publications and speaks on transfer pricing matters at national and international tax events.

Jennifer Paul

Jennifer runs the independent transfer pricing consultancy, Transfer Pricing Consultants Ltd, advising a wide range of clients on planning, documentation and defence.  Jennifer previously worked for Deloitte, and for Ernst and Young, as a Director of Transfer Pricing.

Jennifer’s recent experience includes:

  • Assisting groups to implement new trading structures, for example limited risk distribution arrangements and contract manufacturers
  • Software transfer pricing, in financial products and business information sectors
  • Assisting a global Fortune 100 group to analyse, price and document management services on a pan-European basis
  • Putting in place a worldwide transfer pricing policy for UK plc, taking into account different locations of manufacturing and IP
  • Financial services transfer pricing, including investment management, life assurance and defence of pricing of funds from offshore deposit taker
  • Assisting, training and supervising client staff to prepare ongoing transfer pricing documentation
  • Putting in place tax-efficient royalties for consumer products, automotive components and industrial products
  • Advising an Indian MNE group on its commencement of UK project operations, including transfer pricing and permanent establishment issues

A Chartered Accountant and Chartered Tax Adviser, Jennifer has over 20 years’ experience of working in transfer pricing. In this time Jennifer spent three years working in Milan, advising inward investors, where she learnt business Italian and experienced the practical aspects of business expansion overseas.

Jennifer is a regular contributor to tax publications and speaks at conferences.

Dr. Emmanuel Llinares

Emmanuel is Head of Global Transfer Pricing at NERA Economic Consulting. He is an economist specialising in inter-company pricing, valuation and IP analyses. Emmanuel has managed pricing projects for multinationals in a wide range of industries and the economic analyses in tax-related audits all over the world. Prior to joining NERA, he was an economist with Arthur Andersen in London and KPMG in Paris. He is a former lecturer at the Economics Dept. of the University of Delaware and at the Ecole Supérìeure de Gestion in Paris. He is considered by Euromoney to be one of the world’s leading transfer pricing advisers.

Antoine Faure

Antoine Faure is Attorney at law and graduated of a Business Law Master of the University Lyon III.

Antoine has some 10 years’ experience in transfer pricing and has worked either as a member of an in-house transfer pricing team or as a transfer pricing advisor.

Antoine’s project and industry experience include:

  • Planning and implementation of tax-advantaged supply chain restructurings;
  • Local documentation and co-ordination of global transfer pricing documentations;
  • Preparation and negotiation of advance pricing agreements (APAs);
  • Tax audit assistance;
  • Antoine has experience in various types of intercompany dealings including intangible transactions, cost sharing arrangements and financing transactions.

Industry experience covers chemicals, pharmaceuticals, consumer business, high technology, and finance service industries.

Before joining CMS Bureau Francis Lefebvre, Antoine worked for four years within Deloitte in France and three years in a French pharmaceutical Group where he was allocated regional responsibilities and actively participated on global supply chain strategies, the pricing of new intercompany transactions and numerous post-merger projects. He was also in charge of preparing the global transfer pricing documentation.

US tax compliance for your expatriate clients

John Richardson

John is a Toronto-based lawyer, a member of the Bar of Ontario. He has a niche practice focusing specifically on the problems of US citizens and Green Card holders who (in addition to being subject to US worldwide taxation) bear the burdens of being  tax residents of other countries. In other words, they must successfully navigate and prosper in accordance with he tax and regulatory regimes of two countries. 

John brings  a clear understanding of the legal, tax, retirement planning and investment climate that applies to US citizens abroad and of the US imposed obligations that apply to such individuals. The problems extend far beyond issues of US tax compliance. The problem is also: how do Americans abroad comply with US laws and still engage in financial planning in their country of residence? In order for Americans abroad to engage in responsible financial planning they need specialized advisors. He also provides citizenship counselling for US citizens and around the world.

US citizenship law is complex and has evolved over time. There are many cases where people do NOT believe they are US citizens, but are told that they are US citizens. John helps his clients by first making a citizenship determination, many people turn out to be confused about the status of their US citizenship.

John understands howThe US tax and regulatory regime extends into all aspects of people’s lives. In many cases, Americans abroad do NOT owe US taxes. Yet they are shackled by US regulations that restrict their business opportunities, retirement opportunities and financial planning opportunities. The US tax system even creates additional hurdles for US citizens who marry non-citizens. The weight of these burdens is so significant that many are forced to renounce US citizenship to live a productive life. 
John assists US citizens relinquish/renounce their US citizenship and Permanent Residents abandon their Green Cards. The United States has punitive and confiscatory expatriation taxes that necessitate careful planning.
John sees his role and expertise as counseling people on how to make compliance and citizenship decisions. U.S. citizenship abroad is so difficult and confusing that it is NOT making decisions that is difficult. What is hard is to know HOW to make decisions. He believes that “U.S. citizenship counselling” is really a form of “life counselling”. Decisions made will have a profound impact on the rest of one’s life.

John says: “If one were to ask me what is the service you provide? My answer would be:

I counsel people in the legal, investment and social realities of U.S. citizenship abroad (which is a service that is in short supply and is badly needed).”

Needless to say John also speaks and broadcasts regularly on any and all of these issues both at home in Canada and around the world.