US

True Partners Consulting LLC

633 West Fifth Street, Suite 6200

Los Angeles, CA 90071

US

Office phone: +1 213 417 2501

Fax: +1 213 417 2551

Cell: +1 805 558 9285

Email: cathleen.bucholtz@tpctax.com

Website: www.tpctax.com

Cathleen Bucholtz is the managing director and National Unclaimed Property Practice leader for the Unclaimed Property Solutions Team of True Partners Consulting. Cathleen has extensive experience in all aspects of unclaimed property including audit defence, comprehensive diagnostic reviews, statistical sampling, development of leading practices, and annual compliance. Before joining True Partners Consulting, Cathleen held the Western Region Unclaimed Property Practice leader for KPMG, and before 2002, was part of the National Unclaimed Property Team for Arthur Andersen.

Cathleen has more than 23 years of experience in unclaimed property and state and local tax consulting and auditing, and has represented numerous Fortune 500 clients in the defence of both unclaimed property and sales and use tax audits, resulting in hundreds of millions in total client savings.

Cathleen also has extensive experience in unclaimed property consulting for the healthcare, financial services, insurance, manufacturing, and retail industries.

Before entering public accounting in the late 1990s, Cathleen was a senior sales tax auditor and field audit supervisor for the California State Board of Equalisation.

Cathleen has spoken before numerous trade and professional organisations including the Unclaimed Property Professionals Organisation (UPPO), American Payroll Association, Institute for Professionals in Taxation (IPT), and the National Business Institute (NBI). In addition, she regularly collaborates on unclaimed property seminars geared toward the education of individuals in private industry. Cathleen was recently published in the Spring 2015 issue of the Journal of State Taxation: Frequently Asked Questions About Unclaimed Property.

Cathleen is now serving as the co-chair for the UPPO's Leadership Development Committee. Previously Cathleen served as co-chair for UPPO's Mentors Committee as well as four years as UPPO's Education Committee co-chair, where she helped develop a multi-track educational agenda for the organisation's conferences attended by hundreds of participants annually.

Cathleen earned a bachelor's degree in business economics from the University of California, Santa Barbara and is a licensed certified public accountant (CPA).

McDermott Will & Emery

The McDermott Building

500 North Capitol Street, NW

Washington, DC 20001

US

Tel: +1 202 756 8097

Fax: +1 202 756 8087

Email: eerickson@mwe.com

Website: www.mwe.com

Elizabeth Erickson is a partner in the law firm of McDermott Will & Emery and is based in the firm's Washington, DC office. She is a member of the US & International Tax practice group, and focuses her practice on tax controversies, including tax litigation.

Elizabeth represents clients in disputes before the US Tax Court, US district courts, the Internal Revenue Service Appeals and Examination Divisions, and the Internal Revenue Service National Office. Substantive issues in dispute in these matters have included capitalisation and change in method of accounting issues; captive insurance; accounting for redemption of premium coupons; abandonment loss issues; section 1341 claims; the tax treatment of settlement payments and legal fees, including tax reporting requirements; transfer pricing issues; and tax advantaged transactions. She also has substantial experience assisting clients with alternative dispute resolution techniques at the pre-filing, exam and appeals stages.

Elizabeth is a frequent speaker on tax controversy matters, and was recognised as a 'rising star' in tax controversy in the 2014 edition of The Legal 500 United States. She was also named a 2014 'Tax Controversy Leader' by the International Tax Review.

Elizabeth is the hiring partner for the Washington, DC, office, and is a former co-chair of the Pro Bono and Community Service committee for the Washington, DC office.

Elizabeth is admitted to practice in the District of Columbia.

Her representative experience includes acting in ITOCHU International v American Tire Distributors; Securitas Holdings v Commissioner; Goodrich Corp v United States; USAA v United States and USAA v Commissioner; Capital One Fin Corp v Commissioner; Washington Mutual v United States; Hercules v Commissioner; and Mary Kay Hold Corp v Commissioner.

Elizabeth received her JD (cum laude) from Georgetown University Law Centre, and bachelor's (magna cum laude) and master's degrees in accountancy from Florida State University.

Fenwick & West

801 California Street

Mountain View, CA 94041

US

Tel: +1 650 335 7284

Email: jfuller@fenwick.com

Website: www.fenwick.com

Jennifer Fuller is a senior partner in the tax group at Fenwick & West in Mountain View, California. She was included for the fifth time as one of the world's top 25 women tax advisers in Euromoney's World's Leading Women Business Lawyers (2015).

Jennifer was named 'America's Best in Tax Dispute Resolution' by Euromoney at its 2014 and 2015 Americas Women in Business Law Awards Dinner. She also has been on Euromoney's Women in Business Law shortlist three times for the award 'Best in Tax'.

Jennifer's work during 2015 included large-corporate tax litigation and M&A matters, including work on some of the recent and widely publicised inversion transactions.

Jennifer is on the Executive Leadership Committee of the International Fiscal Association, which is a highly-regarded worldwide association of leading tax advisers, and has appeared regularly in Euromoney's World's Leading Tax Lawyers.

Jennifer has served as the Northern California chair for the California State Bar International Tax Committee. She has spoken at and chaired numerous seminars on international tax subjects, while her articles have appeared in Tax Notes International magazine and in Tax Notes magazine.

Whittier College awarded Jennifer its Alumna Achievement Award in 2013 "for superior accomplishments in her career". Later that year, she was elected to serve on the Whittier College Board of Trustees, a position she still holds.

A tax partner at Fenwick for more than 20 years, Jennifer plays an instrumental role in the firm's tax practice. The firm has represented six of the Fortune top 10 companies, more than 50 of the Fortune 100 and more than 100 of the Fortune 500 companies in federal tax matters.

Jennifer also has been included in Euromoney's Guide to the World's Leading Tax Advisers, Law and Business Research's International Who's Who of Corporate Tax Lawyers, ITR's Leading Lawyers in the Western US, Euromoney's Guide to the Leading US Tax Lawyers, and International Tax Review's Best Tax Advisers in North America.

DLA Piper

1251 Avenue of the Americas

New York, NY 10020-1104

US

Tel: +1 212 335 4582

Fax: +1 212 884 8559

Email: kathryn.keneally@dlapiper.com

Website: www.dlapiper.com

Kathy Keneally serves as the chair of civil and criminal tax litigation in DLA Piper's global tax group. Before joining the firm, Kathy served as the assistant attorney general for the Tax Division of the US Department of Justice (DoJ), where she oversaw the work of more than 350 attorneys in civil, criminal and appellate tax litigation nationwide.

During her tenure as the head of the DoJ Tax Division, Kathy developed and implemented key tax enforcement initiatives in close cooperation with IRS leadership. She worked closely with DoJ leadership, US attorneys, and senior officials at federal and state regulatory agencies, including the Federal Reserve Board of Governors, the New York Federal Reserve, the Securities and Exchange Commission, and the New York Department of Financial Services. As the nation's top tax prosecutor, she oversaw precedential action against financial institutions. Attorney general Eric G Holder, Jr recognised Kathy by awarding her the Edmund J Randolph Award for Outstanding Service to the US Department of Justice and the Nation, the highest honour the Attorney General may bestow on a DoJ employee.

Kathy focuses her practice on civil and criminal tax controversy matters, government investigations, and white collar criminal defence. She has more than 30 years of experience representing large corporations, financial institutions, closely held businesses and high-net-worth individuals in civil and criminal tax matters and non-tax criminal defence matters. She is an experienced trial lawyer, and has also resolved matters with the IRS and other federal agencies without proceeding to litigation. She also assists clients who seek to come into compliance ahead of an investigation.

Kathy is a leader in the legal community. She has served as a vice chair of the American Bar Association Section of Taxation, and chaired two of the Section of Taxation's committees – the Committee on the Standards of Tax Practice and the Committee on Civil and Criminal Tax Penalties. She is now a regent of the American College of Tax Counsel, and serves as a chair of the National Institutes on Tax Controversy and Criminal Tax Fraud.

Recently, Kathy was named by Tax Analysts as one of the top 10 people "who left their mark on policy, practice and administration in 2014".

Ryan

Three Galleria Tower

13155 Noel Road

Suite 100

Dallas, TX 75240-5090

US

Tel: +1 972 934 0022

Fax: +1 972 725 0479

Email: ginny.kissling@ryan.com

Website: www.ryan.com

Ginny Buckner Kissling is president of US operations and principal in Ryan's Dallas office where she leads 1,500 employees across the United States, as well as 230 employees in Hyderabad, India. Ginny is responsible for all aspects of service delivery operations within the United States and India, which includes 19 practices and 81 sub-practices, quality assurance, and business development. She is a technical expert specialising in providing transaction tax services, including multistate audit defence representation, research, reverse audits, and transaction tax education on a national basis. In addition to transaction tax services, Ginny is an industry-recognised expert in the Texas Enterprise Zone Program, which is a business incentive for capital investment and new or retained jobs, and other state and local incentives in Texas.

Ginny lectures on various tax topics for Ryan clients. Additionally, she has appeared as a speaker for the Council on State Taxation, Institute for Professionals in Taxation, Interstate Tax Corporation, National Business Institute, and New York University's Institute on State and Local Taxation. She has written articles for the New York University, Institute on State and Local Taxation and for the Institute for Professionals in Taxation.

She received the 2010 Dallas Business Journal's 40 Under Forty Award and was a 2014 Women in Business honoree. Ginny has served as executive director (1996–2000) and secretary/treasurer (1993–1995) for the Dallas/Fort Worth State Tax Association and held several leadership roles with the Institute for Professionals in Taxation, including chairing the Sales and Use Tax Symposium, chairing the Membership Promotion and Public Relations committee, and serving as a committee member for its annual conference. Additionally, Ginny served as chair, Development Committee (2009-2011); chair-elect, Executive Committee (2012); chair, Executive Committee (2013); and Executive Committee board member (2014) of the Executive Committee of the University of North Texas Department of Accounting Advisory Board. She serves on the advisory board for New York University's Institute on State and Local Taxation, and belongs to the North Prestonwood chapter of the National Charity League.

Ginny holds an MSc degree in accounting with an emphasis in taxation and a BSc degree in accounting, both from the University of North Texas.

Ryan

One PPG Place

Suite 2810

Pittsburgh, PA 15222

US

Tel: +1 412 535 4400

Fax: +1 412 535 4403

Email: helen.lemmon@ryan.com

Website: www.ryan.com

Helen Lemmon is the principal-in-charge of Ryan's Pittsburgh office where she is responsible for quality service delivery of tax services to multinational companies. She also served as Ryan's practice leader for the US credits and incentives practice. Previously, Helen was an office managing partner, regional partner-in-charge of state and local tax (SALT) services, partner-in-charge of US credits and incentives services, and a location leader for SALT at a national accounting firm. Before that, Helen was a SALT manager for a Fortune 500 company.

Helen has served as a board member and co-chair for the Existing Business Committee of the Pittsburgh Regional Alliance, the boards of Girls Hope and Winchester Thurston School, the board of Robert Morris University, the board and executive committee of the Pittsburgh Symphony.

Helen has lectured on business incentives and credits, appearing as a speaker for various clients and organisations, including the Council on State Taxation; the Institute for Professionals in Taxation; New York University, Institute on State and Local Taxation; Tax Executives Institute; and the Texas Taxpayers and Research Association.

She previously co-hosted a radio programme, The Business Journal, discussing relevant business topics with a focus on economic impact. Helen was also featured on Our Region's Business, a business affairs programme co-produced by the Allegheny Conference and Cox Broadcasting that provides business news, information, and commentary related to the Pittsburgh region.

Helen has written articles for The Tax Executive, Pittsburgh Business Times, Construction Accounting and Taxation, and Journal of Multistate Taxation. She was the winner of the 2010 Top 25 Women in Business Awards by the Pittsburgh Business Times and is a certified member (CMI) of the Institute for Professionals in Taxation. She holds a bachelor of science degree from Indiana University of Pennsylvania.

McDermott Will & Emery

227 West Monroe Street

Chicago , IL 60606-5096

US

Tel: +1 312 984 2115

Fax: +1 312 984 7700

Email: jmay@mwe.com

Website: www.mwe.com

Jane Wells May is a partner in the law firm of McDermott Will & Emery and is based in the firm's Chicago office. Jane heads the firm's State & Local Tax practice group and serves on the firm's Management Committee. She focuses her practice on state and local tax matters.

Jane represents businesses in connection with state and local tax controversies at the audit, administrative and judicial levels around the United States. Her clients include companies in manufacturing, retailing, food and beverage, pharmaceuticals, automotive, healthcare, energy, technology and insurance industries. Jane serves as national coordinating counsel to a number of Fortune 500 companies, providing strategic counsel and audit defence on all their state and local tax matters across the country, including litigating in administrative and judicial venues when necessary. She has successfully litigated state and local tax matters raising a variety of statutory and constitutional issues. Jane has defended numerous internet sellers in several states against cases brought under state whistleblower statutes, including the Illinois False Claims Act, alleging fraudulent failures to collect and remit use tax.

Jane also advises business clients on tax planning matters and represents athletes and entertainers in connection with employment contract issues.

A member of the Director's Advisory Group for the State of Illinois, Jane is a regular speaker at seminars on state and local tax issues. She is a member of the Chicago Bar Association's State and Local Tax committee and is admitted to practice in Illinois. Jane has been named a Leading Tax Lawyer in the Legal 500 United States, which states that she has "built a noteworthy local and state taxes practice". She has also been ranked by Chambers USA since 2008, which notes that she "is full of energy and brings a wealth of experience to the work". Furthermore, say the Chambers rankings, Jane is "excellent from an advocacy point of view" and is considered a "strategic leader" in state and local tax. She has also been regularly named an Illinois Super Lawyer in the tax area by Law & Politics.

Jane received her bachelor's degree (with honours) from Wittenberg University in 1980 and her JD from the Vanderbilt University School of Law in 1986. At Vanderbilt University, Jane was senior articles editor of the Vanderbilt Law Review and a member of Order of the Coif and Moot Court Board.

Deloitte Tax

111 South Wacker Drive

Chicago, IL 60606

US

Tel: +1 312 486 9845

Fax: +1 312 247 9845

Mobile: +1 312 927 9845

Email: mimcguire@deloitte.com

Michele is the principal in charge of Deloitte Tax's (US) Customs and Global Trade practice and sits on Deloitte's Global Indirect Tax Executive Committee which manages a network of more than 550 import and export specialists from around the world.

Michele has more than 25 years of experience advising clients on numerous global trade matters. Michele specialises in the operational side of global trade, helping clients assess and design their global trade management process including automated solutions. Michele's deep regulatory and operational background allows her to apply real life practical solutions for her clients, which are not only compliant with a myriad of global trade regulations but are also efficient and effective.

Specifically, Michele has extensive experience in advising Fortune 500 companies in numerous global trade management areas including; global regulatory import and export requirements, first sale for export planning and implementation; optimisation of and compliance in their use of international trade agreements; customs related party valuation compliance and strategy; global import and export risk assessments; designing and implementing global import and export compliance programmes and rollout of automated export and import systems and training.

Before joining Deloitte Tax, Michele was a partner in Andersen's US international trade and customs group. Before Andersen, Michele spent five years as an associate attorney at a Chicago-based law firm where she advised clients on numerous customs and international trade related matters. She also worked as a visiting attorney in the international litigation department of a large London law firm.

Michele earned her bachelor of science degree from Indiana University, juris doctor degree from the John Marshall Law School, and master's of law in international transactions from the McGeorge School of Law in Salzburg, Austria and Sacramento, California. Additionally, Michele is a US licensed customs broker.

Fenwick & West

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 acquisitions, restructurings and transfer pricing issues. She has successfully represented clients in federal tax controversies at the audit level, in appeals and in court.

Larissa appears as a rising star in Euromoney's Guide to the World's Leading Tax Advisers. Euromoney selected Larissa for inclusion in the Americas Women in Business Law Awards shortlist for Best in Tax Dispute Resolution in 2014 and Rising Star: Tax, in 2015.

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. She is the ABA International Law Tax Liaison.

Larissa has published several articles, including recently:

• US Tax Overview, Euromoney's LMG Rising Stars 2015

• US transfer pricing litigation update, International Tax Review (March 2015)

• Areas of TP Scrutiny in a pre- and post-BEPS World, International Tax Review (February 2015)

• US International Tax Developments, The Euromoney Corporate Tax Handbook 2015

• US Transfer Pricing Developments, International Tax Review (2014)

• US Tax Developments, International Tax Review (December/January 2013)

• US International Tax Developments, The Euromoney Corporate Handbook 2012

• Character and Source of Income from Internet Business Activities, The Contemporary Tax Journal (July 2011)

• The Application of the Branch Rule to Partnerships, International Tax Journal (July – August 2010)

Fenwick has one of the world's top tax planning and tax transactional practices, according to International Tax Review (2014 and 2015) and is first tier in tax, according to World Tax 2015. International Tax Review gave Fenwick its San Francisco Tax Firm of the Year award a total of six times and its US Tax Litigation Firm award a total of three times. International Tax Review also named Fenwick its Americas M&A Tax Firm of the Year in 2012.

McDermott Will & Emery

500 North Capitol Street, NW

Washington, DC 20001

US

275 Middlefield Road, Suite 100

Menlo Park, CA 94025

US

Tel: +1 202 756 8297

Tel: +1 650 815 7558 (CA)

Fax: +1 202 756 8087

Email: jpawlow@mwe.com

Website: www.mwe.com

Jean A Pawlow is a partner in the global law firm of McDermott Will & Emery. She serves on the firm's Management Committee and Finance Committee and she is co-chair of the firm's tax controversy practice. US News and Best Lawyers named McDermott 'Tax Litigation Firm of the Year' for 2014.

Jean has been involved in representing businesses and individuals on significant tax controversy matters for 25 years. Substantive issues in dispute have included transfer pricing issues under Code section 482, tax advantaged transactions, tax accounting issues, insurance tax matters, the tax treatment of financial instruments, foreign tax credit and research credit issues, leveraged leases, credit card interchange and original issue discount (OID), excise taxes, reasonable compensation, estate and gift tax issues, and charitable contribution deductions. She also advises on California and District of Columbia state tax controversies.

Jean has litigated cases before the US Tax Court, the Court of Federal Claims, US district courts, US Courts of Appeal and the Supreme Court. She also has extensive experience with IRS alternative dispute resolution (ADR) procedures, including fast track settlement, rapid appeals, post-appeals mediation, pre-filing agreements and CAP audits. She frequently represents clients who are being audited by the IRS Global High Wealth Industry Group.

Jean is a frequent writer and speaker on tax controversy matters and has appeared on CBS and CNBC. She is the contributing editor of a 2015 book on global tax controversies. The Legal 500 has named Jean a leading lawyer every year since 2009, and quoted a client who described her as "a pleasure to work with, clever, an excellent advocate, personable and possessed of an instinctive business understanding". She has been nationally ranked as a leading tax litigation lawyer in every edition of Chambers USA since 2010 as "one of the preeminent tax lawyers in the US" and noted for her "dedication to client service". Jean was also listed in Best Lawyers in America in 2012, 2013 and 2014. She serves on the Tax Committee for the US Court of Federal Claims Advisory Council and is a fellow of the American College of Tax Counsel.

Jean received her bachelor's degree (with high honours) from University of California at Berkeley in 1985 and her JD (cum laude) from Harvard Law School in 1988.

Her representative docketed cases include: Dine Equity v Commissioner; DiMare v Commissioner; Estate of Stanton v Commissioner; John Hancock Life Insurance v Commissioner; Siemens v Office of Tax & Revenue; Novitsky v Siemens; Ambassador Blankenship v Commissioner; USAA v United States and USAA v Commissioner; Goodrich v United States; Boeing v United States; Wal-Mart Stores v Commissioner; and Texas Instruments v Commissioner.