Tax Certainty – Shining a Light on ICAP

Nicole is an OECD Advisor on BEPS issues with specific focus on CbC implementation and the Action 13 peer review. She is the programme lead for the International Compliance Assurance Programme (ICAP). Nicole has 10 years of experience in corporate and international tax and transfer pricing, advising private clients across a multitude of sectors and geographic locations. Her experience focuses on transfer pricing controversy and tax certainty, including MAP, APA and transfer pricing audits. She is a Chartered Accountant (ACA), Chartered Tax Advisor (CTA), and holds an Advanced Diploma in International Tax (ADIT) from the UK Tax Institute (CIOT).

Tadd joined The Procter & Gamble Company in 2005.  He is Senior Vice President – Treasurer, and Global Tax Operations and is located in Cincinnati.  Prior to joining P&G, he was an international tax partner in the Chicago office of PricewaterhouseCoopers, and spent time with General Electric Company early in his career.  Tadd is a frequent speaker at TEI and other tax and international organizations.

Karen S. Kirwan is a Senior Advisor to the Director, Treaty and Transfer Pricing Operations (TTPO) in the IRS Large Business & International Division (LB&I). Karen has primary responsibility to provide strategy-level analysis and advice on significant issues to the TTPO Director. Responsibilities include planning, coordinating, and implementing technical and resource management projects and programs within the Treaty and Transfer Pricing Operations.
Before joining the IRS in 2016, Karen was part of EY’s National Tax Department, Transfer Pricing group where she advised clients on a wide variety of transfer pricing issues from documentation to planning and audit support, including cost sharing issues and advance pricing agreements.

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.