IADC International Tax Seminar

Monday, 1 June 2026

2:00–5:00 pm  IADC Tax Committee Roundtable Aspen Room (Committee Members Only, separate registration required)

Teusday, 2 June 2026

7:45 am  Registration & Coffee Service  Crystal Foyer

8:15 am  Welcome & Opening Comments  Crystal Ballroom

• Christian Ochoa, Chairman, IADC Tax Committee; Vice President – Tax, Valaris

8:20 am  U.S. and Canada Tax Developments Affecting Independent Drillers: Implications of OBBBA, Pillar II, and Expanding Disclosure Requirements: Matt Martin, Assurance Associate, Bret Oliver, Tax Partner, Eugene Quo, Tax Partner, Faith Omekaodinma, Tax Director, PwC
This presentation examines significant U.S. and Canadian tax developments affecting independent drilling contractors. In the U.S., it focuses on the operational and financial reporting implications of the One Big Beautiful Bill Act (OBBBA), the emerging global minimum tax framework under Pillar II, and the expanded income tax disclosures under ASU 2023-09. In Canada, a strategic shift in policy relating to the Oil & Gas industry is creating compliance and investment implications for drilling contractors. Key considerations include capital investment, depreciation, multi-state activity, and compliance expectations across drilling operations.

9:15 am  ASC740 Guidance Update: Amy Ruday, Business Tax Services Partner, KPMG Houston, Jenna Summer, ASC 740 Partner, KPMG Washington National Tax
This session will include various items of relevance, but with a specific focus on lessons learned from the financial disclosure requirements under ASU 2023-09 and quarterly disclosures required in 2026 (for public calendar year filers).  Will also include a discussion of presentation items relevant to structures common in the drilling industry.     

10:00 am  Coffee Break

10:30 am  Oil & Gas Transfer Pricing – Strategies for Navigating Periods of Sustained Volatility: Bill Macey, Partner – International Tax & Transaction Services, Rio Waechter, Senior Manager – International Tax and Transaction Services, Ernst & Young LLP
Presentation will address the impact of industry volatility on transfer pricing for drilling companies, including an overview of transfer pricing challenges during market uncertainty for drilling companies, how companies can proactively monitor and react to swings in oil prices, rig utilization and capex and key strategies to reduce transfer pricing risk and ensure compliance in uncertain environments.

11:15 am CFO Roundtable 
Hear from leading industry finance executives as they share how investors are evaluating the drilling sector amid economic volatility and how the expansion of energy sources impacts on and offshore drillers.  Gain insight into the market forces shaping capital allocation, valuation, and strategic priorities across the industry.  In addition, hear what these finance executives have to say about the role the tax function plays in their organizations. 

• Moderator: Stuart Vogt, VP Corporate Tax, Transocean Ltd.
• Chris Weber, SVP & CFO, Valaris
• Darcy Reynolds, VP of Finance & CFO, Akita Drilling
• Mike Gray, CFO, Ensign
• Thad Vayda, CFO, Transocean

12:15 pm  Luncheon Alberta Ballroom

Beneath The Surface – The Hidden Compliance Risk in Oil & Gas: Mike Kenehan, Partner, Anne Rachko, Partner, Ricardo Garcia, Partner, Andersen
Unclaimed property compliance and reporting remain complex and frequently underestimated areas of risk within the oil and gas industry. This panel discussion will provide practical guidance to help industry professionals identify key compliance exposures, strengthen internal controls, mitigate audit risk, and reduce the potential for interest and penalties.

1:30 pm  It Was Big, But Was it Beautiful?: Jen Acuna, Federal Legislative and Regulatory Services Principal, KPMG Washington National Tax, Jeff Hiller, International Tax Managing Director KPMG Houston
It’s been nearly 11 months since the passage of the One Big Beautiful Bill and with a major election cycle on the horizon, what’s next on the US tax  legislative and regulatory front, and what does it mean for the taxpayer experience?

2:05 pm Developments on Brazilian Tax Reform on Consumption & Repetro and RFB Assessments in 2025: Carolina Bottino, Partner, Eduardo Telles, Partner, Mayer Brown
As of 1 January 2026, Brazilian Tax Reform on Consumption is effective and all drillers must be in compliance with the new legislation and rules. In addition, new agreements are now entered considering this, which might increase drillers costs in Brazil. Considering this new scenario and regulations that must be published until December 2026, it is necessary to continue to discuss the impacts of the Brazilian Tax Reform on Consumption to drillers activities in Brazil.

2:30 pm Middle East Tax Landscape Focusing Primarily in UAE: Speaker to be named, Deloitte
Discussion will cover the evolution of newly introduced UAE Corporate tax and its impact to foreign multinationals doing business in UAE.  This includes key provisions such as Participation Exemption rules, qualifying Freezone Person rules subject to 0% tax and conditions need to be met, how DIFC and ADGM has evolved into latest holding company structures for US companies doing business in UAE and any latest tax updates from Ministry of Finance and Federal Tax Authority.  We will also give an Introduction of OECD based Pillar 2 rules in the wider middle east and key updates/development and a brief corporate tax overview of wider Middle East region.

3:15 pm  Coffee Break

3:40 pm  Africa Update: Gilles de Vignemont, Managing Partner, Vignemont Africa & Partners, Stephanie Mpinwa, Partner, TaxAfrica Ivory Coast
Our presentation will focus on 3 current hot spots for the drilling industry in Africa: the Republic of Congo, Ivory Coast and Mozambique. Congo: we will cover the uncertainties linked to VAT exemptions and highlight potential solutions. We will also provide practical ideas connected to recent new drilling models (rigs operated by a third Party) to avoid double taxation. Ivory Coast: we will provide updates on the scope of exemptions available to drillers and will highlight the impact of the new local content regulations. Mozambique: we will provide an update on the “force majeure” lifted by some of the E&P companies operating there and will highlight potential exemptions available to drillers under the Petroleum Licenses.

4:15 pm  The Changing Landscape of Tax Controversies: Rob Morris, Partner, Norton Rose Fulbright
Discussion of the latest tax controversy topics applicable to IADC members.

5:00 pm  Welcoming Reception Sponsored by Norton, Rose, Fulbright  Oak Room

Wednesday, 3 June 2026

8:00 am  Registration & Coffee Service  Crystal Foyer

8:20 am  Welcome & Opening Comments Crystal Ballroom

• Christian Ochoa, Chairman, IADC Tax Committee; Vice President – Tax, Valaris

Moderator: Christian Ochoa, Chairman, IADC Tax Committee; Vice President – Tax, Valaris

8:25 am  Global Controversy: Alison Smith, Tax Senior Manager, Niels Muller, Partner, Hilde Thorstad, Tax Lawyer, PwC
This presentation will examine the current landscape of tax authority examinations and tax dispute resolution around the world, with a special focus on European jurisdictions. With Pillar 2 creating increasing complexity, companies are looking to stay ahead of tax audits and also to expend resources prudently in a tight market for tax departments. US issues will be addressed in a separate session.

8:50 am  European Holdco’s & Pillar 2 update from the Trenches with Less than 4 Weeks to Go
Despite the OECD’s release of the Side-by-Side Package  (SbS) aiming to substantially carve out the US from Pillar Two, Europe continues to be committed to the OECD’s global minimum tax. However, can SbS also be considered some sort of silver lining for non-US headquartered MNEs or is it too little too late for Europe’s holding jurisdictions? This session will discuss questions such as these, along with general updates from Europe beyond Pillar Two and an initial “lessons learned” from the first Pillar Two compliance season from across the pond.

• Herko Koekkoek, Tax Partner KPMG Netherland
• Deborah May, Tax Partner, KPMG Aberdeen
• Michael Smith, Tax Sr Mgr, KPMG UK desk in NYC
• Michael Ayachi, Tax Partner, KPMG Luxembourg desk in NYC
• Diego Lipp, Tax Sr Mgr, KPMG Swiss desk in Seattle

9:15 am Love Is Blind: Sjaak de Pagter, International Tax Partner, Daniel McMaster, International Tax Partner, EY Houston, Alexander Pouchard, International Tax Partner, EY Luxembourg, Miklos Santa, International Tax Partner, EY Hungary
There are several popular jurisdictions for rig companies—either for holding assets or intercompany financing instruments. Each country offers different options to attract investment. In this session, three contestants will participate in a ‘dating show’ in which the contestants ask questions of 3 different countries to what opportunities and risks each presents to see which country can successfully woo the contestants to invest in their country.

10:00 am  Coffee Break 

10:30 am Mexico’s 2026 Tax Reform: Strategic Implications for the Oil & Gas Industry: Irene Hernandez, Federal Taxes Partner, Mario Alberto Gutierrez, International Tax Partner, PwC Mexico
This presentation will examine Mexico’s 2026 income tax reform and amendments to the Amparo Law, and how they will shape the fiscal landscape for multinational oil and gas firms. It will provide insights on rule design, alignment with global standards (including BEPS), and risks and opportunities for upstream, midstream and EPC operators. The scope covers income tax updates and measures affecting deductions, permanent establishment, and cross-border transactions, and how the Amparo framework may influence judicial remedies in fiscal and customs disputes. Based on legal analysis, SAT positions audits and court precedents, it outlines compliance expectations and ways to leverage treaties, adjust operating models, and maintain documentation. The reform tightens restrictions, imposes stricter documentation and reporting, and narrows avenues to challenge assessments. The session will offer guidance linking tax policy to operations and impacts on financing, bidding, and compliance.

11:10 am P2 US Carve Out: Speaker to be named, Deloitte

11:50 am Is Now the Time to Redomesticate?: Joshua Odintz, Partner, Holland & Knight
In light of the OBBBA and changes to Pillar Two, is now the time to move to the U.S.? The presentation will address the pros and cons of moving to the United States

12:25 pm Luncheon  Alberta Ballroom
Strategic Mobility and Immigration Planning for Rotational or Project Workers: Roxanne Israel, Partner/Principal, Ernst & Young LLP, Kristie Ketron, Executive Director, People Advisory Services Tax, Tyler Robson – Partner, People Advisory Services Tax, Ernst & Young LLP
Global projects and offshore rotations demand proactive planning to navigate immigration and mobility tax requirements. This session will equip attendees with insights on evolving immigration and tax trends, compliance risks, and planning considerations for assignments. A panel of experts will discuss practical strategies to mitigate visa delays and optimize compliance. Attendees will be better able to anticipate compliance requirements and navigate the shifting immigration landscape more confidently and strategically.  This presentation will focus on solutions and messaging specific to the drilling industry – applying best practices and lessons learned across industries and timely updates in an ever-changing mobility landscape.

1:40 pm  Pillar II Update- Are we done yet? Compliance Year 1 and what’s next: Chetan Vagholkar, International Tax Partner, KPMG Houston, Swati Herwadkar, International Tax Managing Director, KPMG San Francisco
Session will include a discussion of the filing experience of clients with 2024 returns due in 4 weeks and an overview of where Pillar II is headed

2:20 pm  Strategic Modeling & Forecasting to Empower Tax Leadership in Financial Transformation: Speaker to be named, Deloitte
Presentation will respond to growing compliance burdens, explore evolving compliance expectations and their impact on Tax functions. understand how modeling can streamline compliance response and reduce risk and demonstrate practical examples of models that track and predict compliance outcomes.

3:00 pm  Adjournment

• Christian Ochoa, Chairman, IADC Tax Committee; Vice President – Tax, Valaris