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Managing Tax Risk in a Changing World

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Rapid business transformation across the globe and shifting international policy are driving significant changes to organizations’ tax exposure, financial resilience, strategy and management. These factors are shaping how companies across every sector approach the future of tax dispute resolution.

Our latest report draws on an independent survey of 1,200 tax leaders in 10 jurisdictions and across six sectors conducted in late 2021 and insights from our tax disputes and international tax teams to uncover:

  • How tax risk is reshaped looking at the current environment, trends and key drivers of disputes, including a changing business and policy landscape
  • A relentless rise in tax risk threatening organizations’ financial resilience
  • A shift in tax exposure and strategy
  • A need to build a disputes mindset to face new challenges
Author

Allen Tan is the head of the Tax, Trade and Wealth Management practice in Baker McKenzie Wong & Leow. He has extensive experience working on both international and local tax issues, with a special focus on the regional tax aspects of the transactions that he is involved in. Allen’s clients include Global Fortune 500 multinational corporations and major Singapore conglomerates. He is recognised as a leading lawyer for his tax controversy and corporate tax work in many leading legal and tax directories including International Tax Review, Chambers Asia Pacific and Legal 500 Asia Pacific. Allen was also named the Asia Tax Practice Leader of the Year 2018 by International Tax Review.

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Caroline Silberztein is nominated by France on the list of independent persons of standing authorized to serve as arbitrators for the application of the European Arbitration Convention. She is a member of the United Nations Sub-Committee on Transfer Pricing and continues to be involved in policy dialogue with OECD and non-OECD countries. She is a visiting Professor in several European Universities. She was the Head of the OECD Transfer Pricing Unit from 2001 to 2011.

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Jukka Karjalainen is a partner in the London Tax Department of Baker McKenzie, and co-leads the UK Transfer Pricing practice as well as sits on the Firm's EMEA transfer pricing steering committee. He has 25 years of experience in dealing with transfer pricing and international corporate tax issues from both a private practice and an industry perspective, having spent time in-house at a multinational metals and mining corporation.

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Kai R. Kramer is a member of the Tax Practice Group in the Firm’s Houston office. Prior to joining Baker & McKenzie LLP, Mr. Kramer was a tax associate at another international law firm in Washington, DC where he handled tax matters related to a broad mixture of domestic and cross-border transactions across the energy, financial institution (including banks and insurance companies), pharmaceutical, and high-tech industries.

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Katarzyna Kopczewska is a partner in Baker McKenzie's Warsaw office. She combines legal background with 13 years' tax advisory experience from a Big Four consultancy with a focus on real estate.

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Scott Frewing represents clients in complex civil and criminal tax matters, as well as other complex financial investigations and litigation. He has successfully defended taxpayers from some of the largest transfer pricing cases brought by the US Internal Revenue Service, obtained multiple tax refunds in excess of USD100 million, and successfully represented financial institutions and individuals in IRS and US Department of Justice investigations relating to offshore tax accounts and other allegations of tax fraud. Earlier in his career, Mr. Frewing was a federal prosecutor and was a founding member of the US Department of Justice’s first Computer Hacking and Intellectual Property Unit.

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María Antonia Azpeitia heads the Firm’s Tax Litigation and VAT practice groups in Madrid. She is ranked as a leading practitioner in her field by Chambers Europe, and is highly regarded for her work on VAT matters. She is a regular lecturer in tax seminars and conferences, and contributor to economic newspapers and other specialized publications.

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Roberto Cardona is a member of the Tax Practice Group in Baker McKenzie since 2003, and is currently the leader in Public / Administrative Law practice in Mexico. Roberto has published several articles on tax and administrative opportunities for Baker McKenzie and specialized magazines. Roberto has also been an exhibitor at seminars and conferences sponsored by the Firm.

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George Clarke is a partner in Baker & McKenzie’s North America Tax Practice Group in Washington, DC. His practice focuses on tax litigation and he is nationally-known for his work in civil and criminal tax matters. Mr. Clarke has authored several articles on tax law and is a contributor to the Forbes IRS Watch Blog as well as other blogs and publications. He is consistently recognized by Legal 500 as a leading adviser in tax controversy. Mr. Clarke also lends his talent to pro bono matters and has successfully represented non-enemy combatants unlawfully detained by the US in Guantanamo Bay, Cuba. He is a certified public accountant (inactive). Before becoming a lawyer, he served in the US Marine Corps.

Author

Barbara Faini is a tax litigator and a member of Baker McKenzie’s Tax Dispute Resolution Group. She has extensive experience in the major areas of tax law, including cross-border and domestic transactions, application of tax treaties and partnerships’ tax issues, VAT and customs duties issues. She has particular experience in private banking and employees benefits. She was admitted to the Supreme Court in 2012.

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David is a partner and has represented clients in VAT disputes for over 15 years at all stages of the litigation process. He specialises in resolving high-value VAT disputes working primarily with clients in financial services and telecommunications and e-commerce sectors.

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Jorge Narváez-Hasfura is a partner in Baker McKenzie's Mexico office. With 32 years of experience, he has been voted as a leading tax practitioner in Mexico on tax litigation, transfer pricing and indirect taxation by the International Tax Review. He has been nominated to appear in the Guide to the World's Leading Transfer Pricing Advisers. He has been voted as one of the leading tax practitioners in Mexico by Chambers & Partners every year since 2011, and praised by well-known international publications for his transfer pricing and corporate reorganization work alongside his very strong practice in tax rulings, treaties and litigation.

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Thanh Vinh Nguyen is a partner in Baker McKenzie's Ho Chi Minh City office. Prior to joining the Firm, he practiced tax and consultancy work for two international accounting firms and worked as a compliance counsel for an international insurance company. He has co-written Business Operations in Vietnam, published by The Bureau of National Affairs, Inc.

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Daniel A. Rosen is a partner in the North America Tax Practice Group in New York. He is a seasoned tax lawyer with over 16 years of experience with the Internal Revenue Service. Mr. Rosen was a key participant in the drafting of published guidance and administrative directives involving judicial doctrines for the IRS Large Business and International Division (LB&I). He served as IRS counsel in many cases that resulted in published opinions and is a frequent speaker for George Washington University School of Law, the Practising Law Institute, Tax Executives Institute and the ABA. Additionally, Mr. Rosen served during law school as business editor of the Hofstra Law Review. He is an adjunct professor of law at New York Law School.

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Susan E. Ryba is a tax controversy partner in the Firm's Chicago office. She also heads the Chicago Tax Practice Group, is a member of the Chicago office management committee, and serves as the Chicago office hiring partner. Ms. Ryba specializes in federal tax controversy matters. She advises clients in a wide variety of industries, with a particular focus on companies in the technology, pharmaceutical, healthcare, and retail industries.

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