Tax Certainty – Moving Beyond the Status Quo

Jonathan Fraser is an Advisor in Tax Certainty Unit of the OECD's Centre for Tax Policy and Administration (CTPA). In this role, he contributes to OECD's work on the Tax Challenges Arising from the Digitalisation of the Economy (Pillar 1 and Pillar 2) and on BEPS Action 14, including operational tools to promote greater tax certainty for MNE groups and tax administrations (including MAP, Advanced Pricing Agreements, International Compliance Assurance Programme (ICAP), risk assessments, CbC Reporting and Joint Audits). He joined the OECD in 2021. Prior to joining the OECD, he worked in international tax and transfer pricing consulting in Australia and held roles within the Australian Government providing advice in taxation policy and legislative design. Jonathan is a qualified lawyer in Australia. He holds undergraduate degrees in law and international business and holds a Master of Law in corporate, commercial and taxation law. 

Rick is an accomplished international tax lawyer with high-level tax advisory and controversy experience in Europe and the US.  While in Europe, he served as the senior EMEA tax executive for three public companies and was a fiscal advisor to the Luxembourg government of Jean Claude Juncker.  Rick graduated from Duke University, got his law degree at UNC-Chapel Hill, and his LL. M in taxation at Georgetown Law Center. 

Sonja is Senior Manager, Global Tax Controversy at Netflix, where she leads the global tax controversy function and strategy.  Prior to joining Netflix in January 2022, she was Principal Corporate Counsel at Microsoft, where she was the lead attorney managing international income tax controversies, including audits, administrative appeals, competent authority proceedings, and litigation and engagement on advance pricing agreements and tax rulings. Before Sonja joined Microsoft in 2018, she worked in the Chicago offices of Skadden, Arps, Slate, Meagher & Flom LLP and Baker & McKenzie LLP, where she advised individuals and multinational corporations at various stages of U.S. federal income tax controversies, including in U.S. Tax Court and federal court litigation.

Nicole Welch is the director of the Advance Pricing and Mutual Agreement program (APMA) in the IRS Large Business and International (LB&I) division, where she oversees the negotiation and resolution of all mutual agreement procedure and advance pricing agreement cases arising under U.S. tax treaties. Nicole currently is serving as the acting director of the Treaty and Transfer Pricing Operations practice area in LB&I. She has served as a delegate to several OECD working groups, including the Forum on Tax Administration MAP Forum. Before joining the IRS, Nicole handled international tax planning and controversy matters at a law firm in Washington, DC.