Hot spots of cross-border uncertainty around the world include disputes related to permanent establishment, transfer pricing, deployment of intangibles, and business structuring.  Panel members will explain how taxpayers can manage these disputes, such as in competent authority, and will share their views on the practicality of using advance pricing agreements. 

· David Swenson, Principal, PwC (Moderator)

· Michael Danilack, Deputy Commissioner (International) - Large Business and International Division, Internal Revenue Service

· Mary Bennett, Head of the Tax Treaty and Transfer Pricing Division, OECD Centre for Tax Policy and Administration

· Simon J. Beaumont, Vice President-Tax, IBM Corporation

· Kevin Conway, Senior Vice President, Tax & Treasury, Warner Music Group

Chief Financial Officers face difficulties in attempting to manage the consequences of uncertainty in the current U.S. tax system.  This panel will address the tax system's effect on business transactions, investment decisions, supply chain, global risk management, and job creation, among other issues. To bring these issues into sharper focus, the Symposium will feature a dialogue among three CFOs on strategies and best practices.

· George Forster, Deputy Tax Leader and WNTS Leader, PwC (Moderator)

· David J. Anderson, Senior Vice President and Chief Financial Officer, Honeywell International

· Gregory Hayes, Chief Financial Officer, United Technologies Corporation

· Jon R. Moeller, Chief Financial Officer, The Procter & Gamble Company

As tax policies of countries around the world evolve to address economic and fiscal difficulties, issues develop with regard to the administration of those policies. This panel will discuss approaches to tax administration in panelist countries that address these needs through pre-filing and post-filing initiatives.

· Timothy Tuerff, Partner, Deloitte Tax LLP (Moderator)

· Geoff Lloyd, Director- Dispute Resolution, HM Revenue and Customs (United Kingdom)

· Richard Montroy, Deputy Assistant Commissioner- Compliance Programs Branch, Canada Revenue Agency

· Joel W. Walters, Group Corporate Finance Director, Vodafone Group Services Limited

The impact of the growing federal budget deficit, the increased concerns about the competitiveness of US multinationals, and the lack of certainty in the tax law are driving the push for comprehensive tax reform. This panel will examine specific policies to advance the goal of a stable U.S. tax code that promotes job growth and business expansion.  The panel members will explore policy options that include a competitive corporate tax rate, a predictable tax base, incentives for innovation, and deployment of new productive plant and equipment.

· Pamela F. Olson, Partner, Skadden, Arps, Slate,  Meagher & Flom LLP (Moderator)

· Mike Fryt, Corporate Vice President, Tax, FedEx Corporation

· John M. Samuels, Vice President and Senior Counsel, Tax Policy and Planning, General Electric Company

· Eric Solomon, Partner, Ernst & Young LLP

· Andrew B. Lyon, Principal, PwC

This session will identify specific ways to improve the administration of U.S. tax law, increase the flow of reliable guidance, and promote a more collaborative and transparent working relationship between the IRS and taxpayers.

· Larry Gibbs, Member, Miller & Chevalier Chartered (Moderator)

· Heather C. Maloy, Commissioner -  Large Business and International Division, Internal Revenue Service

· William Wilkins, Chief Counsel, Internal Revenue Service

· Robin Beran, Director, Tax & Trade and Assistant Treasurer, Caterpillar Inc.

· Barry Shott, Managing Director, PwC