IADC International Tax Seminar

Wednesday, 5 June 2024

2:00–5:00 pm  IADC Tax Committee Roundtable  Margaux1 (Committee Members Only, separate registration required)

Thursday, 6 June 2024

7:40 am  Registration & Coffee Service  Margaux Foyer

8:10 am  Welcome & Opening Comments Margaux 2
Stuart Vogt, Chairman, IADC Tax Committee; VP Corporate Tax, Transocean Ltd.

8:15 am  IADC Washington, DC Update: Joe Lillis, Vice President, Policy, IADC
Joe will talk about IADC’s presence in DC, recent lobbying efforts, legislative actions in Congress, DC Fly-Ins, and DrillersPAC, IADC’s political action committee and how attendees can get more involved.

8:30 am  Pillar 2 & ASC 740 It’s Really Happening:  Jenna Summer, Partner, Jared Huish, Partner, Jeff Hiller, Managing Director, Amy Ruday, Managing Director, KPMG
This session will overview day one readiness, provision reporting matters and working with your financial auditors, recasting deferreds, perm treatments, how it works, and elections.

9:20 am  Australasia & Asia Regional Update: Speaker to be named, Deloitte

10:10 am  Coffee Break

10:35 am  Pillar 2 & Driller Issues:  Bret Oliver, Partner, Hilde Thorstad, Partner, Alison Smith, Director, PwC
Pillar 2 discussion focusing on driller related issues, including rig movements, CODI, bankruptcy, fx, owner operated and BBC structures, M&A, audit settlements, tripartite agreements and other unique structures and debt. 

11:25 am European Regional Update: Miklos Santa, Partner, EY Hungary, Richard Kocsis, Managing Director, EY US Global Tax Desk
Provide update on significant tax developments in key European Union countries that are most relevant to the drilling sector, including latest Pillar 2.0 updates, trends on tax audits, and proposed legislation that could be enacted in the near future.

12:15 pm  Luncheon  Margaux 1

Foreign Exchange – Friend or Foe in International Tax: Rod Gibbons, Director, Willow Gibbons, Ballycatter Group Inc.
From personal finance to business activities, how foreign exchange is handled within international tax can have a significant impact on the bottom line.  This paper describes lessons learned from a quarter century of personally moving money internationally and a winning strategy for maximizing value through currency exchange in international transactions.

1:30 pm  What’s Ahead in the Tax Legislative Landscape: Navigating Election Year Politics & the Looming 2025 Tax Cliff: Jennifer Acuna, Principal, KPMG
This session will examine the tax legislative landscape for what remains of the current Congress and evaluate tax legislative options and potential outcomes, for the upcoming Congress through the lens of the 2025 tax cliff.  

2:20 pm  Pillar 2 Tax Provision & Reporting Readiness: Paul Wagoner, International Tax Senior Manager, Quantitative Consulting Group National Office, Leslie Coye, Senior Manager International Tax , Deloitte
Understanding the Pillar 2 computation, from TSH, QDMTT, IIR, and UTPR.  Potential differences by jurisdiction, the matrix of IIR/UTPR reporting with complex ownership chains, how the P2 tax return may look, timing of cash payments, constant change of guidance  and focuses on challenges in the current landscape including data collection, processes, and calculations.

3:10 pm  Coffee Break

3:35 pm  New World of Tax & Transfer Pricing in LATAM for the Drilling Industry: Gene Tien, Principal Economist, Baker & McKenzie Consulting LLC, Luis Carbajo-Martinez, Principal, Baker & McKenzie Abogados, S.C., Maria F. Furtado, Principal, Trench, Rossi e Watanabe Advogados
Brazil’s alignment with the OECD tax and transfer pricing guidelines creates a major shift to the tax landscape in Latin America, but it is only one part of a trend toward a new world of taxation across the region.  For example, countries like Mexico have become more active in conducting tax audits, and transfer pricing controversy has become more meaningful.  However, these trends are not without their tax planning opportunities.  This session will focus on developments in Latin American tax in key jurisdictions that affect the companies in the contract drilling industry.

4:25 pm  IRS Controversies of the Present & Future: Rob Morris, Norton, Rose, Fulbright
The presentation will cover some of the IRS’s new compliance initiatives in federal tax enforcement, including transfer pricing and economic substance. 

5:05 pm  Welcoming Reception  Margaux 1  Sponsored by Norton, Rose, Fulbright

Friday, 7 June 2024

8:00 am  Registration & Coffee Service  Margaux Foyer

8:25 am  Welcome & Opening Comments: Stuart Vogt, Chairman, IADC Tax Committee; VP Corporate Tax, Transocean Ltd.

Moderator: Stuart Vogt, Chairman, IADC Tax Committee; Tax Director, Transocean Ltd
8:30 am  US Regional Update: Lauren Dangelmayr, Partner, Owen Holladay, Director, PwC
Update on various US tax matters, including transfer pricing and international tax developments.

9:20 am Charting a New Frontier: Adapting Existing Transfer Pricing Models to the Evolving Global Transfer Pricing Landscape: Nick Gaudioso, Jr. Sr. Manager, Mayank Gautam, Managing Director, Randy Price, Managing Director, Deloitte Tax, LLP
 A tax and economic overview of current transfer pricing models for the contract drilling industry, key risk areas, and best practices for tax practitioners in the evolving transfer pricing landscape. Futhermore, we will discuss key areas of tax controversy across the contract driller value chain for traditional transfer pricing models related to financing, rig valuations, and intangible property use.

10:10 am  Coffee Break 

10:35 am Pillar 2 Guidance & Plans: Sjaak de Pagter, Partner, Daniel McMaster, Partner, EY International Tax Services
Update on the latest BEPS Pillar 2 developments and trends that could have an impact on company’s financial position, how to deal with changing guidance (retroactive, trends, OECD procedures and current state of P2 enactment). Discuss differences in the manner that countries have adopted BEPS Pillar 2 rules that may create uncertainty for tax departments and how those uncertainties may be resolved. How the US may respond, the UN and African and Latin American response, P2 definitions of leasing, and impact on debt and internal financing, (3.2.7 and 2.6.3), and opportunities which may exist.

11:25 am Middle East/Africa/India Overview: Vincent Lacombe, Partner KPMG France & Africa Tax Coordinator, Anjani Sharma, Partner, KPMG India NYC Resident, David Leeds, Managing Director, KPMG
This session will provide an update on corporate tax matters in the Middle East, Africa, and India.

12:15 pm Luncheon  Margaux 1

Tax & Sustainability: Niels Muller, Partner, Energy Transition & Sustainable Energy, Charalambos Antoniou, Partner, PwC
Discussion of latest developments on sustainability efforts in Europe, the US and beyond.

1:30 pm  Tax Reform, Repetro-Sped & Transfer Pricing updates in Brazil: Carolina Bottino, Partner, Ivan Tauil, Founder & Tax Partner, Eduardo Telles, Tax Partner, Tauil & Chequer Advogados in association with Mayer Brown
After more than two decades of discussions, in 2023 the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on consumption was enacted. The reform significantly changes the current taxation of goods and services, substituting the indirect taxes in force by a dual Value-Added Tax (IVA). In addition, a new law was approved which introduced new Transfer Pricing rules aimed at aligning the Brazilian system with the OECD standard. Finally, Drillers faced significant challenges on the import of drilling rigs in Brazil due to new interpretation of the Repetro-Sped legislation by Brazilian Tax Authorities. This scenario brings Brazil into the spotlight again and the necessity to understand how to do business in the country.

2:20 pm  Tax Technology Developments & Best Practices:  Aaron Puiszis, Partner,  EY Tax Technology and Transformation
Discuss and showcase latest trends in technologies that tax departments are utilizing to automate activities, manage data risks, utilize artificial intelligence, and provide value to organizations.

2:55 pm  Adjournment: Stuart Vogt, Chairman, IADC Tax Committee; VP Corporate Tax, Transocean Ltd.