Host: Mark Nehoray, partner, Deloitte Tax LLP
On October 12, the G20/OECD Inclusive Framework on BEPs released two Blueprints that could fundamentally change longstanding rules governing international taxation of large multinational entities. What should tax executives know? We’ll discuss:
- The first Blueprint—technical progress on Pillar 1’s revisions to rules for allocation of profits to market jurisdictions without regard to the arm’s length standard and nexus/permanent establishment.
- The second Blueprint—technical progress on Pillar 2’s proposed approach to establishing a global minimum tax and backstop regime that denies deductions or imposes withholding in cases of certain payments to low-tax jurisdictions.
- Unilateral actions already being taken by countries around the world.
Meet the speakers
Mark is a senior partner in the Los Angeles office of Deloitte Tax LLP. He is a founding member of Deloitte’s national transfer pricing practice in March 1990, as well as the founding member of its Los Angeles transfer pricing practice. Mark has more than 36 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas. He consults with multinational clients on transborder transactions, assists multinational companies with transfer pricing studies, and consults with clients on restructuring of foreign royalties and other foreign income streams. Mark led the team that successfully negotiated Mexico’s first-ever transfer pricing ruling.
Bob advises the US companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation and Development (OECD). Bob joined Deloitte Tax from the US Department of the Treasury (Treasury), where he was the deputy assistant secretary for international tax affairs in the Office of Tax Policy. While there, he worked directly with the assistant secretary of tax policy and the international tax counsel in developing and implementing all aspects of US international tax policy, including treaties, regulations, and legislative proposals. He also was the official representative of the Obama administration for international tax policy and represented the US government at the OECD where he was involved in all aspects of the Base Erosion and Profit Shifting initiative. Prior to joining Treasury, Bob had more than 25 years of experience in international tax matters, representing both corporations and individuals. Bob is a member of the executive committee of the US Branch of the International Fiscal Association (IFA) and a frequent speaker at IFA events worldwide. He a member of the advisory committee for the Annual Institute on Current Issues in International Tax at The George Washington University School of Law. He is a frequent speaker at events sponsored by such organizations as the Tax Executives Institute, the International Bar Association, American Bar Association Tax Section, and Irish Tax Institute. He presented the Twenty-Second Tillinghast Lecture on International Taxation at the New York University School of Law. Bob earned his Bachelor of Arts in English education from State University of New York at Albany and his Master of Arts in French language and literature from New York University. He went on to obtain his Master of Science in foreign service from Georgetown University and a Juris Doctor from Georgetown University Law Center, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.