The Competing Forces & Compromises Shaping Tax Policy

Continental Breakfast and Registration

Welcome Remarks and Recognition of Symposium Mission

Keynote Address

Speaker TBA

Charting the Future of US Policy amid Budget Deficits and Government Debt

This session will review current data and projections of the federal government’s fiscal situation, including spending categories and revenue sources. Panelists will focus on the economic growth, revenue, and fiscal imbalance impacts of tax policies in play in 2025. This session also will examine the implications of the interaction between monetary and fiscal policy changes.

Moderator:
- Paul Nolan, Vice President, Tax, Government Affairs & Strategic Real Estate, McCormick
Speakers:
- Christine Dobridge, Principal Economist, Federal Reserve Board of Governors
- Bill Hoagland, Senior Vice President, Bipartisan Policy Center
- John McClelland, Director of Tax Analysis, Congressional Budget Office

The Economics of Tax Policy - Revenue Estimates and Broader Impacts

Revenue estimating and broader economic analysis play a critical role in shaping tax policy by providing lawmakers with data necessary to make informed legislative decisions and to comply with legislative procedural requirements. This session will review briefly the role of revenue estimates in the legislative process, examine the key players in revenue estimation and the methodologies they apply for producing static, conventional, and dynamic estimates. Panelists also will address emerging issues in revenue estimating, including the impact of global minimum tax initiatives on revenue projections, how the interaction between US and foreign tax policies is reflected in estimates, and the challenges in estimating the revenue effects of climate and energy-related tax incentives.

Moderator:
- Brandon Pizzola, Partner, Quantitative Economics and Statistics Group, EY
Speakers:
- Tim Dowd, Senior Economist, Joint Committee on Taxation
- Jane Gravelle, Senior Specialist in Economic Policy, Congressional Research Service
- Hank Gutman, Of Counsel, Ivins Phillips & Barker

Break

What the Demise of Agency Deference Means for the US Tax Environment

The Supreme Court decision in Loper Bright struck down the Chevron doctrine that called for judicial deference toward agency rulemaking. The full consequences of this decision are still being understood across the executive branch overall and for tax specifically. What standard of judicial review will apply in lieu of Chevron going forward? What is the impact on both the regulatory and legislative process? And how will Loper Bright change the litigation tactics of both taxpayers and the government? This session will explore these questions and provide perspectives on the post-Chevron tax landscape.

Moderator:
- Armando Gomez, Partner, Skadden Arps Slate Meagher & Flom
Speakers:
- Michael Desmond, Member, Miller & Chevelier
- Pam Grewal, Managing Director, US National Tax, Andersen
- Brett York, Principal, PwC

The Current US Tax Legislative Landscape

The US tax legislative landscape is dynamic and subject to rapid change. This session will focus on the current status of US tax legislative activity and the topics and developments of the day. Panelists will provide diverse views from across the tax policy spectrum, share lessons learned and experiences from prior tax legislative initiatives, and discuss practical implications for companies as they navigate volatility and uncertainty.

Moderator:
- Adam Francis, Principal, Washington Council EY
Speakers:
- David Noren, Partner, McDermott Will & Emery
- Shannon Stafford, Managing Director, The Carlyle Group
- Anna Taylor, Deputy Leader - Tax Policy Group, Washington National Tax, Deloitte Tax

Lunch & Presentation of the 2025 TCPI Pillar of Excellence Award

2025 Pillar of Excellence Award Recipient TBA

Renewing the Focus on Elimination of Double Taxation

Avoiding double taxation has historically been a central policy objective of international tax rules, both in domestic legislation and in tax treaties. This objective has been pursued through a variety of approaches, including foreign tax credit systems, exemption systems, and mutual agreement procedures. Recently, other policy objectives have loomed large, exacerbating the potential for overlapping taxation and constraining tax administration resources for resolution of disputes over taxing rights. This session will focus on the importance of the historical objective of double-tax elimination and the current challenges around it.

Speakers:
- Danielle Rolfes, Partner in Charge, Washington National Tax, KPMG
- Josh Ruland, Principal, National Tax Department, EY

The Future Trajectory of Global Minimum Taxes

Under current law, there is a complex overlap of both local minimum taxes (e.g., QDMTTs and CAMT) and cross-border minimum taxes (e.g., IIR, UTPR, and GILTI). These overlapping minimum tax regimes, together with regular corporate income tax regimes, create significant complexity, invite controversy, and risk double (and more) taxation of the same income. Recently, the Trump Administration and the U.S. Congress have signaled that they will act to reduce the impact of certain of these rules on U.S. businesses. This session will explore the future trajectory of Pillar Two, GILTI, and CAMT.

Moderator:
- Rocco Femia, Member, Miller & Chevalier
Speakers:
- Alyson Lawrence, Vice President, Global Taxation, Johnson & Johnson
- Scarlet Pereira, Executive Vice President - Tax, Mastercard
- Tom Roesser, Tax Policy Counsel, Microsoft

Global Taxing Rights in a post-Pillar One Environment

The motivations that prompted the Pillar One project still exist. Specifically, to the extent that market jurisdictions believe that historic norms have resulted in an under-allocation of taxing rights, they may address their concerns by unilaterally enacting digital services taxes (DSTs), expanded nexus rules, and other measures. This session will focus on the current state of Pillar One, DSTs and similar taxes, and the path forward.

Moderator:
- Daniel Smith, Director, International Tax Planning & Policy, Alphabet/Google
Speakers:
- Mindy Herzfeld, Professor of Practice, University of Florida Levin College of Law
- John Stowell, Senior Vice President – Tax, Incentives & International Financial Reporting, Disney

Break

Keynote Address

Speaker TBA

The Life of a Tax Director in Today’s Global Economy

This session will address practical operational challenges faced by tax directors, including changing talent needs in accounting and tax, global mobility issues, transparency and data reporting, and the role of investor relations and communications in tax. Panelists also will discuss ideas for updating skills and strategies to help the tax department partner with other corporate functions on tax communications.

Moderator:
- Lisa Wolski, Managing Director, Washington Council EY
Speakers:
- Melissa Hall, Senior Vice President, Assurant
- Tony Santiago, President, TaxSearch, TaxForce, & TaxTalent
- Mark Volpe, Senior Vice President, Tax, Regeneron

Networking Reception

Continental Breakfast

Welcome Back

Keynote Address

Speaker TBA

Tariffs and Industrial Policy – Effects on Markets and Bottom Lines

This session will explore the evolving role of tariffs and industrial policies, looking at both the historical context and the modern implications for businesses. Panelists will discuss the economic and trade policy implications of these policies, as well as potential financial reporting and tax transparency considerations. This session also will focus on approaches for addressing these practical challenges in an increasingly interconnected global economy, in which tariffs are becoming a tool to help drive a variety of economic and policy outcomes.

Moderator:
- Andrew Phillips, Co-Director, Quantitative Economics and Statistics Group, EY
Speakers:
- Kristin Bohl, Principal, PwC
- Jennifer Hillman, Co-Director, Institute of International Economic Law, Georgetown University Law Center

The Global Tax Dialogue - The Objectives, Players and Venues

Global tax cooperation has evolved significantly in recent years, with a marked change in the role of multilateral organizations. There has been a shift in primary focus from model tax treaties, transfer pricing approaches and fostering common understandings to developing and seeking to mandate broader standards for international and domestic tax policy. This session will focus on the objectives of tax cooperation and the implications of this mission shift. Panelists will discuss how the OECD, Inclusive Framework, UN, and key regional tax organizations conduct their work, the risk of duplication of efforts versus the potential for complementarity, and the opportunities for input from business stakeholders.

Moderator:
- Michael Plowgian, Principal, Washington National Tax, KPMG
Speakers:
- Barbara Angus, EY
- John Bates, Principal, Deloitte
- Kevin Nichols, Head of Tax Policy and Strategic Projects, Uber

Break

The Growing Use of Technology in Tax Administration

This session will explore how the IRS and other tax administrations are increasing their use of technology, especially AI. In a time of increased focus on government efficiency and budget cuts, innovations in the use of new technology may help the IRS quickly adapt to shifting resources and priorities. Panelists will discuss what tax administrations are doing differently and how businesses can be ready for these new technology advancements.

Moderator:
- Nikole Flax, Principal, National Tax Service, PwC
Speakers:
- Rebecca Friedman, Partner, Data & Technology Transformation, IBM
- Caitlin Tharp, Tax Controversy and Litigation Associate, Steptoe LLP

Charting a Path Forward

During this final session, senior tax leaders will share their key takeaways from the two days of symposium discussions. The conversation will focus on strategies for forging ahead through the ongoing wave of challenges and uncertainty.

Moderator:
- Colleen O’Neill, Leader, National Tax Department, EY
Speakers:
- Tadd Fowler, Senior Vice President – Treasurer and Global Tax Operations, Procter & Gamble
- Paul Hoogsteden, Head of US and Canada Tax, Novo Nordisk
- Chris Miller, Senior Vice President – Tax, T-Mobile
- Urvi Doshi Sood, Vice President, Taxes & General Tax Counsel, Lockheed Martin

Closing Remarks