IADC International Tax Seminar

Start: 7 June 2018
End: 8 June 2018

Venue: Hyatt Regency Austin
Location: Austin, TX, USA

Conference Sponsors



Registration Information

Click Here To Register Online For This Event

  • Registration for this event is $575 per attendee.  IADC/SPE/PESA/IAGC members only.
  • Speakers and sponsors are not eligible for online registration. (Complete the Conference Registration Form PDF below)
  • In order to receive a letter of invitation, IADC requires payment via Wire Transfer. The wire transfer information is included on the registration form. (Complete the Conference Registration Form PDF below)
  • Click here to download the Conference Registration Form (PDF format)

Conference Links

For questions regarding the conference, please contact Stephanie Carling at stephanie.carling@iadc.org or +1.713.292.1945.

IADC/SPE/PESA/IAGC members only.
No prerequisites are required.
CPE’s are available for this event!


Worldwide tax issues affecting the drilling and producing industry will be addressed at this seminar. IADC tax seminars are geared to both specialists and non-specialists. Continuing education credits will be offered for tax specialists.  The 2018 theme is “Managing Challenge, Disruption and Transformation”.

Conference Program

Wednesday, 6 June 2018

2:00-5:00 pm  IADC Tax Committee Roundtable  (Committee Members Only)  Texas 1 
Separate registration is required at http://www.iadc.org/event/iadc-tax-committee-2/.

Thursday, 7 June 2018

7:45 am  Registration & Coffee Service  Zilker Foyer
Sponsored by Ernst & Young LLP 

8:15 am  Welcome & Opening Comments  Zilker 3-4

  • Steve Hayes, Chairman, IADC Tax Committee; Sr. Vice President- Tax & Asset Management, Transocean

8:20 am   Chairman’s Panel
During the past three years, we have seen sweeping global changes in tax policy as a result of BEPS, increased scrutiny on transfer pricing, a notable increase in aggressive tax audits, an unexpected cap on the bare boat charter in the U.K., submission of country-by-country reports, disclosure of proprietary tax rulings and now the biggest tax reform in the U.S. in over 30 years.  Mr. Hayes will pose questions to the panel to set the stage for the seminar.

  • Kathryn Horton O’Brien, Principal, Transfer Pricing, PricewaterhouseCoopers LLP
  • Jon Cross, Tax Manager, Ensco plc
  • Linda Ibrahim, Vice President- Tax & Governmental Compliance, Vantage Drilling

9:10 am  U.S. Tax Reform-Welcome Back to Inbound Planning In a Post Tax Reform World
In late December, President Trump signed into law the most sweeping changes to business-related federal income tax in over three decades.  The speakers will discuss inbound planning in a post tax reform world, including insights on managing BEAT, inbound financing and possibilities for repatriation.

  • Alex Hanhan, Partner, KMPG LLP
  • Chetan Vagholkar, Partner, KPMG LLP
  • Ron Dabrowski, Partner, KPMG LLP

10:00 am  Coffee Break  Sponsored by Ernst & Young LLP 

10:30 am  Structuring Asset Ownership in a World of BEPS & State Aid Enforcement
The panel will review the jurisdictions and commonly used financing and bare boat charter structures that should be reconsidered in the EU for state-aid, MLI, ATAD or domestic reasons as well as jurisdictions like Luxembourg and Hungary.  The presentation will also address the practical aspects and the impact of the Country-by-Country Reporting initiative in the context of the operating models generally applied in the Industry and will include a tax update regarding the Middle- East jurisdictions in the context of the recent international tax law changes.

  • Alex Pouchard, Partner, Ernst & Young LLP
  • Miklos Santa, Partner Tax Services, Ernst & Young LLP
  • David Evans, Associate Partner, Ernst & Young LLP

11:15 am  U.S. Tax Reform-Application of GILTI
In late December, President Trump signed into law the most sweeping changes to business-related federal income tax in over three decades.  The speakers will discuss the practical application of the Global Intangible Low Taxed Income (“GILTI”) on the drilling indsutry.

  • Leslie Alston, Partner, PricewaterhouseCoopers LLP
  • Pat Berrigan, Partner, PricewaterhouseCoopers LLP

12:00  Luncheon    Zilker 1-2
Sponsored by PricewaterhouseCoopers LLC

Featured Presentation: M&A in the Post-Tax Reform World
The speakers will discuss inbound planning in a post tax reform world, including thoughts on managing BEAT, inbound financing and possibilities for repatriation.

  • Gregg Byers, Partner, PricewaterhouseCoopers Finance
  • Doug Meier, Deals Leader – Greater Texas Market, PricewaterhouseCoopers LLP

1:10 pm  Transfer Pricing Panel
The panel will discuss current issues, policies and practices in transfer pricing including the impact of BEPS and the implications of U.S. tax reform.

  • Randy Price, Managing Director, Transfer Pricing, Deloitte Tax LLP
  • Kelly Hales, Principal, Ernst & Young LLP
  • Lauren Dangelmayr, Director, PricewaterhouseCoopers LLP

1:50 pm  The Future of Supply Chain Planning: The Drilling Industry Value Chain
The speakers will discuss U.S. and BEPS aspects of the Supply Chain and Value Chain and its implications to the drilling industry.

  • Jonathan Martin, Partner, Baker McKenzie
  • Gene Tien, Director of Economics, Baker McKenzie
  • Jukka Karjalainen, Tax Leader Business Transformations, Baker McKenzie

2:30 pm  Coffee Break  Sponsored by Ernst & Young LLP   

3:00 pm  U.S. Tax Controversy & Litigation
The presentation will discuss how to approach IRS Appeals under the new procedures and provide a summary of tax cases relevant to the drilling industry.There have been recent changes in how IRS Appeals conducts itself, including allowing IRS Exam to participate in the IRS Appeals conferences.  The change requires taxpayers to be on guard when taking a case to IRS Appeals.  In addition, there are a number of significant tax cases that are of interest to the drilling industry and multi-nationals.

  • Shawn O’Brien, Partner, Mayer Brown LLP
  • John Hildy, Partner, Mayer Brown LLP

3:55 pm  Blowback-International Response to U.S. Tax Reform
Several foreign governments threatened pushback on U.S. tax reform due to their view that certain provisions may violate formal and informal global agreements regarding fair taxation. Finance ministers from Europe’s largest economies and from the European Commission implored Treasury Secretary Mnuchin to consider potentially distortive impacts on international trade. One publication characterized U.S. tax reform as representing a thinly disguised form of trade war.  At the same time, Europeans hinted that certain U.S. tax reform provisions could endanger existing double-taxation treaties or face challenge as illegal export subsidies.

  • Kelly Hales, Principal, Ernst & Young LLP
  • John Fiorito, Partner, Ernst & Young LLP

4:50 pm  Welcoming Reception   Zilker Terrace
Sponsored by Norton Rose Fulbright LLP  

Friday, 7 June 2018

8:00 am  Coffee Service  Sponsored by Ernst & Young LLP 

8:15 am  Welcome & Introduction  

  • Steve Hayes, Chairman, IADC Tax Committee; Sr. Vice President- Tax & Asset Management, Transocean

8:20 am  Update on North Sea Taxation
The panel will discuss recent changes to the taxation of companies operating in the North Sea, including hot topics from the U.K., the Netherlands, Denmark and Norway.  We will discuss recent developments arising from the Anti Tax Avoidance Directive, proposed changes to lease accounting and taxation and changes to withholding tax rules and as well as an update on the hire cap. 

  • Alan McCrae, Partner & UK and EMEA Head of Energy Tax, PricewaterhouseCoopers LLP
  • Niels Muller, Partner, PricewaterhouseCoopers LLP
  • Tobias Steinø, Partner, PricewaterhouseCoopers LLP
  • Hilde Thorstad, Partner, PricewaterhouseCoopers LLP

9:10 am  Financial Reporting for Income Taxes & other GAAP Standard Changes   

  • Rupiah Vadapalli, Partner, Deloitte Tax LLP
  • Alice Loo, Managing Director, Deloitte Tax LLP
  • Paul Rasmussen, Sr. Tax Manager, Deloitte Tax LLP

10:00 am  Coffee Break  Sponsored by Ernst & Young LLP 

10:30 am  Special Presentation

  • Speaker to be named, Norton Rose Fulbright

11:15 am  Country Focus: Luxembourg & the Netherlands
A discussion of recent tax and political developments in two countries of interest to the drilling industry- Luxembourg and the Netherlands

  • Christian Bednarczyk, Partner, Deloitte Tax LLP
  • Willem Gooskens, Director, Deloitte Tax LLP

12:00  Luncheon  

Featured Presentation: Taxation in an Increasingly Digitized World
This session will focus on emerging technology solutions and how they are impacting the tax function.  Specifically, we will cover market trends, disruptive technologies and opportunities across the tax function, allowing the participants to identify what has changed in the technology landscape over the past year, understand what disruptive technologies are and how they may affect your business and see possible automation/efficiency opportunities that exist due to the constantly changing technology landscape.

  • Richard Littleton, Sr. Manager, Deloitte Tax LLP

1:10 pm  Country Focus: Australian Tax Developments- Is Australia an Outlier or Setting New International Precedents?
Moderator: Cliff Mangano, Director Global Transfer Pricing, Diamond Offshore Drilling Inc.
Australia has recently experienced an unprecedented wave of new multinational tax rules and enforcement activity. With some of these reforms, Australia is “part of the crowd’. However, other reforms (diverted profits tax, harsh penalties) and proposals (debt pricing, offshore commodity marketing hubs, mobile asset leasing arrangements) have put Australia at the front of the pack in post-BEPS multinational tax reform. Some positions adopted by the ATO, such as its views on transfer pricing methods for mobile asset leasing, represent a major departure from conventional industry practice accepted by other tax authorities around the world. This session will discuss recent developments relevant to the drilling industry as well as the potential wider global ramifications as governments and tax authorities across the globe look to protect and grow their corporate tax bases in a post-BEPS world.

  • Hamish McElwee, Partner, PricewaterhouseCoopers LLP
  • Olivier Marion, Partner, PricewaterhouseCoopers LLP
  • Paul McCartin, Partner, PricewaterhouseCoopers LLP

1:50 pm  Country Focus: Africa-Tax & Regulatory Developments Affecting the Drilling Industry
The presentation will focus on PE risks, local content, regulatory compliance and a short discussion of key developments.  Throughout Africa, BEPS continues to trigger changes, including an increased focus on PEs and the tightening of anti-avoidance rules under the Multilateral Convention. 

  • Silke Mattern, Partner & Pan African Tax Desk Leader, Ernst & Young LLP
  • Elvis Ngwa, Tax Manager, Ernst & Young LLP

2:30 pm  Country Focus: Brazil’s New Tax Rules for Oil & Gas Activities
Insightful discussion on recent changes in tax legislation related to oil & gas activities in Brazil. In 2017, the Brazilian government changed the taxation of charter agreements as well as the rules for the special Repetro customs regime.  These changes directly impact the import of rigs into Brazil and consequently the drilling industry.

  • Carolina Bottino, Partner, Tauil & Chequer Advogados
  • Ivan Tauil, Head of Tax-Partner, Tauil & Chequer Advogados
  • Eduardo Telles, Partner, Tauil & Chequer Advogados

3:05 pm  Adjournment

Sponsorship Opportunities

There are four levels of sponsoring: Diamond sponsors, Platinum Sponsors, Gold Sponsors, and Silver Sponsors. Event sponsorships are also available and will be categorized by monetary contribution with the appropriate level of sponsorship. Please find the benefits of the sponsor packages below. The conference sponsor will receive high profile recognition before, during and after the conference.  No refunds for cancellations will be issued.

Diamond Sponsor Header

Diamond $25,000
(10 Comps*)


Platinum $15,000
(5 Comps*)


Gold $10,000
(3 Comps*)


Silver $5,000
(1 Comp*)


Event sponsorships are also available!

For more information please contact:

Stephanie Carling, stephanie.carling@iadc.org, or Lori Gagula, lori.gagula@iadc.org at +1.713.292.1945.

* Comps refer to number of complimentary registrations

Hotel Information

Please make your room reservations directly with the hotel.
Please be sure to mention IADC to obtain discounted rate.

Hyatt Regency Austin
208 Barton Springs
Austin, Texas, USA, 78704
Phone: +1.512.477.1234
Single/Double Occupancy……..$219
Rates available until 15 May 2018.
Click here to make your reservation online.

Warning: Please note that there is a company named Exhibition Housing Services (EHS) actively approaching conference delegates and exhibitors by phone and email trying to sell hotel rooms at the Hotel for a cheaper rate than the published rate on this conference website. Please note that Exhibition Housing Services does not represent IADC or the hotel, nor has IADC or the hotel authorized EHS to use their names or trademarks on information they send out to exhibitors and delegates.

To avoid being a victim of fraud, please do not give out your credit card details to any other party and make your hotel reservations exclusively through the Hotel.


Press Policy

Complimentary press registration is limited to one (1) person per company. This individual must be a titled editor, writer, reporter or other bona fide editorial representative of a legitimate industry or consumer publication. Publishers and sales and marketing specialists are excluded from this complimentary registration practice and must pay the full conference registration fee to attend an event.

The IADC International Tax Seminar is advertised in industry publications media including:

Click the logo to visit: Click the logo to visit:
DC Logo Events Footer Upstream Logo Events Footer

IADC provides web links as a member service. IADC does not warranty or endorse the accuracy or reliability of any of the information, content, or advertisements contained on websites linked to www.iadc.org or any of its subsidiary pages.

Event Summary

IADC International Tax Seminar