US

True Partners Consulting LLC

225 West Wacker Drive Suite 1600

Chicago, IL 60606

US

Tel: +1 312 235 3323

Email: alexis.bergman@tpctax.com

Website: www.tpctax.com

Alexis Bergman is a tax director in the international tax group of True Partners Consulting based in Chicago. Alexis advises multinational corporations on their most complex business transactions, developing and implementing integrated business tax solutions to enhance operational and tax efficiencies, while complying with the US federal tax laws.

With a career spanning 20 years within Big 4 firms and for a Fortune 500 company, Alexis has extensive experience analysing and structuring international transactions, including cross-border mergers and acquisitions, reorganisations, principal and finance company arrangements, intellectual property realignment strategies, repatriation techniques, subpart F planning, foreign tax credit planning, foreign currency transactions, local country tax planning, transfer pricing, and the financial statement accounting for transactions under ASC 740.

Alexis is a skilled certified public accountant (CPA) with a Bachelors of Business Administration degree in accounting from Loyola University Chicago and a master's degree in tax from DePaul University. She is a member of the American Institute of Certified Public Accountants, the Illinois CPA Society, and the International Fiscal Association, US Branch.

KPMG LLP

1800 K Street NW

Suite 1200

Washington, DC 20006

US

Tel: +1 202 533 3127

Email: mcorwin@kpmg.com

Website: www.kpmg.com

Manal S Corwin is KPMG LLP's national service line leader for international tax as well as principal in charge – international tax policy for KPMG's Washington national tax practice. In addition, Manal leads KPMG International's global BEPS network and advises clients on developments and implications of BEPS measures. She rejoined KPMG in April 2013, following completion of her tenure as deputy assistant secretary of tax policy for international affairs in the US Treasury Department.

At the US Treasury Department, Manal helped shape the administration's views and policies in all areas of international taxation and worked closely with the Internal Revenue Service, members of Congress, and key tax regulators globally. In addition, she was involved in shaping the administration's framework for tax reform and was head of the delegations responsible for negotiating income tax treaties with Japan, Spain, Chile, and the UK. Manal also served as the US delegate and vice chair to the OECD's committee on fiscal affairs and was actively engaged in the origination and development of the OECD BEPS initiative. Significantly, Manal was also responsible for leading the development and implementation of the intergovernmental approach to the Foreign Account Tax Compliance Act (FATCA), which has been endorsed as the foundation for a global standard for automatic exchange of information.

Prior to joining the Treasury Department (first as international tax counsel in the office of tax policy and then as deputy assistant secretary for international tax affairs), Manal was a principal in KPMG's Washington national tax practice from 2001 to 2009, where she advised multinational corporations on US international tax aspects of their operations and transactions and represented clients in tax controversies before the IRS.

Earlier in her career, Manal served as the deputy and then acting international tax counsel in the office of tax policy at the US Treasury Department. Prior to that, Manal practiced as an attorney specialising in international taxation at the law firm of Covington & Burling in Washington, DC. Manal also served as a judicial clerk for then Chief Judge Levin Campbell on the US Court of Appeals for the First Circuit.

True Partners Consulting LLC

400 North Ashley Drive Suite 1600

Tampa, FL 33602

US

Tel: +1 813 434 4017

Email: sonali.fournier@tpctax.com

Website: www.tpctax.com

Sonali Fournier is a managing director in True Partners Consulting's Tampa office. She joined the firm in February 2007 and has more than 14 years of experience in federal and international taxation. Sonali works with clients in the areas of federal income tax, international tax, FAS 109 – provision for income taxes, and FIN 48 – uncertain tax positions.

Sonali's industry focus has been in services, retail, and manufacturing. Prior to joining True Partners Consulting, she spent seven years at PwC, starting in Atlanta, Georgia, where she specialised in international taxation. She transferred to PwC in Tampa and focused on federal and international tax for multinational clients.

Sonali provides tax compliance and consulting services to large multinational clients in the Florida area. She has broad-based knowledge in the areas of FAS 109 tax provision analysis including deferred and tax payable studies, purchase accounting, and APB 23 analysis. She also has experience in outbound structuring of business operations and international compliance. Additionally, she has been involved with structuring international taxation strategies for multinational companies, including: international reorganisations and acquisitions, evaluation of international tax treaties, repatriation planning, foreign tax credit planning, foreign currency and financing transactions, global and local country tax planning, and analysing corporate structures to minimise subpart F income.

Sonali received her Bachelor of Science degree from the University of Central Florida and received both her Masters of Science in policy studies degree and her Masters of Professional Accountancy degree from Georgia State University. She is a member of the American Institute of Certified Public Accountants and the Florida Institute of Certified Public Accountants.

Mayer Brown

1221 Avenue of the Americas

New York, NY 10020-1001

US

Tel: +1 212 506 2639

Fax: +1 212 262 1910

Email: egladney@mayerbrown.com

Website: www.mayerbrown.com

Erin G Gladney is a tax controversy partner in Mayer Brown's New York office. Erin represents clients in all stages of federal tax controversies, including audits, administrative appeals, and litigation. Her experience includes controversies involving transfer pricing, advance pricing agreements, economic substance, substance-over-form doctrines, and summons enforcement. Erin also has experience defending against civil tax penalties and preserving taxpayers' attorney-client privilege and work product protection during audit, appeals, and litigation.

Aptis Global

4370 La Jolla Village Drive, Suite 400

San Diego, CA 92122-1249

US

Tel: +1 858 433 2701

Email: kkimball@aptisglobal.com

Website: www.aptisglobal.com

Kathrine A Kimball is the managing principal and founder of Aptis Global LLC, headquartered in San Diego, California.

Kathrine began her transfer pricing career in 1993 by formulating the analysis for the Yamaha Motors US case. Today, Kathrine has nearly 25 years' experience in global transfer pricing, value chain analysis, intangible property valuation and migration, and supply chain transformation tax planning. Kathrine operates in the areas of international tax planning, tax effective supply chain strategy, transfer pricing documentation and defence, having served clients across all major industries. As a truly global transfer pricing adviser, she has served clients around the world: most recently as a global transfer pricing principal with Deloitte, previously as a vice president of CRA, and as a principal with EY, having built practices in Washington, DC, Brussels, San Francisco, and San Diego.

Kathrine is a frequent speaker within international tax circles as well as at corporate and philanthropic events as a motivational speaker in the areas of servant leadership and mentoring. Kathrine holds an MBA from the College of William & Mary and a BBA from Loyola Marymount University. She has been named consistently among the world's leading transfer pricing advisers in the expert guide published by Euromoney's Legal Media Group as well as in International Tax Review's Women in Tax Leaders guide. She has also been named consistently by in-house counsel and colleagues on Euromoney's shortlist for the Americas Women in Business Law award.

Mayer Brown

1221 Avenue of the Americas

New York, NY 10020-1001

US

Tel: +1 212 506 2265

Email: kmikolaitis@mayerbrown.com

Website: www.mayerbrown.com

Kristin M Mikolaitis is a partner in the tax controversy practice in Mayer Brown's New York office. Since joining the firm in 2008, Kristin has represented taxpayers at all stages of federal tax controversies, including during audit, in administrative appeals, and before federal courts. Kristin's controversy experience includes major corporate tax matters involving international tax and transfer pricing, substance-over-form disputes, economic substance issues, financial and leasing transactions, and civil tax penalties. Her litigation experience includes extensive pre-trial and trial work in the US Court of Federal Claims and the US Tax Court, as well as matters in various US courts of appeals. Kristin has also actively participated in the firm's pro bono efforts by representing individuals in tax, landlord-tenant, and estate planning matters.

Kristin serves on the firm's committee on diversity and inclusion, hiring committee, and litigation training committee, and the New York office's women's forum steering committee. She also serves on the National Women's Law Centre's leadership advisory committee and is co-chair of its pro bono services and public policy sub-committee.

Fenwick & West LLP

Silicon Valley Center

801 California Street

Mountain View, CA 94041

US

Tel: +1 650 335 7253

Email: lneumann@fenwick.com

Website: www.fenwick.com

Larissa Neumann focuses her practice on US tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience. She has successfully represented clients in federal tax controversies at the audit level and in IRS appeals, the US Tax Court and in other federal courts.

Larissa's keen analytical skills coupled with her focus on providing clients practical solutions to complex tax issues have earned her a reputation as a leading tax adviser both in the Silicon Valley and nationwide. Larissa appears in Euromoney's World's Leading Tax Advisers and International Tax Review's Tax Controversy Leaders guide.

Larissa teaches international tax at the University of California, Berkeley Law School and co-authors a monthly column in Tax Notes International.

Larissa was counsel in the recent important taxpayer Tax Court victory involving transfer pricing for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the 2017 successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11-647T. She also is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15, a pending Tax Court case that involves § 367(d) and § 482.

Euromoney's Women in Business Law named Larissa as America's Best Transfer Pricing Lawyer in 2017. She also was named by Euromoney as one of the world's leading transfer pricing advisers (2017).

Larissa appears in Euromoney's Women in Business Law (a shortlist of the top women tax lawyers in the world) and International Tax Review's Women in Tax Leaders guide. Euromoney Women in Business Law shortlisted Larissa twice for the award of America's Best Lawyer in Tax Dispute Resolution.

Larissa was named to the Daily Journal's 2017 list of Top Women Lawyers in California and was honoured with the Women of Influence award by the Silicon Valley Business Journal in 2017. In 2016, Larissa was named a Rising Star in tax by Law360 and named in the Silicon Valley Business Journal's 40 Under 40.

Larissa frequently speaks at conferences for professional tax groups, including the Tax Executives Institute, International Fiscal Association, Pacific Rim Tax Institute, Bloomberg, and the American Bar Association (ABA). She is the ABA international law tax liaison.

Fenwick has one of the world's top tax planning and tax transactional practices, according to International Tax Review, and is a first tier firm in tax, according to World Tax. Fenwick is consistently named the San Francisco Tax Firm of the Year by International Tax Review and has been named US Tax Litigation Firm of the Year a number of times.

Mayer Brown

1221 Avenue of the Americas

New York, NY 10020-1001

US

Tel: +1 212 506 2799

Fax: +1 212 849 5743

Email: leahrobinson@mayerbrown.com

Website: www.mayerbrown.com

Leah Samit Robinson leads Mayer Brown's state and local tax group and is a member of the tax transactions and consulting practice. A partner in the firm's New York office, she advises public and private business entities on state and local tax planning, controversy and litigation.

She provides national and state tax strategy and audit assistance for clients on a full range of tax matters, including nexus, combination and apportionment, and net operating loss issues. She is the co-author of the chapter on 'Appeals' in State Business Taxes (Law Journal Press 2009).

Leah regularly advises on the sales tax characterisation of goods and services, with a particular focus on digital services and software as a service issue. Leah has litigated a number of sales tax cases but is sensitive to most companies' preference to resolve matters without litigation.

She is particularly well-known for her advocacy in New York City and New York State, as well as for advising on the impact of the massive New York tax reform undertaken in 2014 and 2015. She was appointed to the New York City Department of Finance Commissioner's advisory board (2014-present), as well as to the city's pass-through taxation working group (2014-present), a think tank formed by the Department of Finance to assist with bringing reform to the city's unincorporated business tax. Leah has been a principal drafter of six reports issued by the New York State Bar Association Tax Section, commenting on tax reform legislation and proposed draft regulations and one report issued by the New York City Bar Tax Section. She is the author of the 'In a New York Minute' column published by State Tax Notes.

Leah is also well known for her advocacy in New Jersey tax disputes, covering income tax and sales tax matters. Leah was counsel or co-counsel in disputes related to New Jersey's now-defunct throw-out rule (Pfizer), taxation of extraterritorial income (IBM), treatment of limited partners (Preserve II), taxation of partnerships (Pulte Homes), apportionment of income from securitised loan portfolios (Capital One), and sales taxation of temporary help services (Labor Ready) and electricity distribution charges (Atlantic City Showboat). She has been appointed to the New Jersey Supreme Court's committee on the tax court (2017-2018 term) and authors the State Tax Notes column, 'The Jersey Short–Everything You Need to Know about New Jersey Tax'. She is an editor of Bloomberg BNA's Corporate Income Tax Navigator (New Jersey).

Previously, as a tax lawyer with the IRS office of chief counsel in New York City, she was part of the strategic trial team handling the largest section 482 transfer pricing controversy in history.

Fenwick & West LLP

Silicon Valley Center

801 California Street

Mountain View, CA 94041

US

Tel: +1 650 335 7848

Email: jushakova-stein@fenwick.com

Website: www.fenwick.com

Julia Ushakova-Stein focuses her practice on US tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, mergers and acquisitions, and transfer pricing. She represents clients from a diverse set of industries and geographic areas. She has represented a number of Fortune 500 companies in US federal income tax matters and has successfully represented clients in federal tax controversies at all levels.

Julia is representing VF Corporation, and is preparing for trial in the US Tax Court on a section 367(d) issue involving a $1.4 billion income adjustment by the IRS. This closely watched case involves a cutting-edge tax approach to international M&A. Julia also was counsel in Conversant et al. v. Commissioner, Tax Court Docket No. 030476-14, and was on the trial team that won Analog Devices, Inc. & Subsidiaries v. Commissioner, 147 T.C. No. 15 (November 22 2016).

In some noteworthy transactions, Julia represented Facebook in its $2 billion acquisition of Oculus, which won International Tax Review's Consumer Products Deal of the Year award; Goldman Sachs and 13 major New York banks in their investment in Symphony Communications, which won International Tax Review's Joint Venture of the Year award; JP Morgan, Barclays and ICAP in their investment in Cloud9 Technologies LLC, which was shortlisted for International Tax Review's America's Banking Tax Deal of the Year award; and General Motors in its acquisition of Cruise Automation, a leader in autonomous driving technology, which was shortlisted for International Tax Review's America's Consumer Products Tax Deal of the Year award.

Julia received Euromoney's Americas Women in Business Law Awards Rising Star: Tax in 2017 and appears in Legal Media Group's 2017 Expert Guides: Rising Stars publication.

In addition, Julia speaks at conferences for professional tax groups and has published a number of international tax and transfer pricing articles.

Fenwick is a first tier firm in tax planning, tax transactional, and transfer pricing, according to International Tax Review. Fenwick & West was named San Francisco Tax Firm of the Year eight times by International Tax Review. Fenwick also was US Tax Litigation Firm of the Year three times and received multiple ITR M&A tax awards including Americas M&A Tax Firm of the Year.