IADC International Tax Seminar

Wednesday, 4 June 2025

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

Thursday, 5 June 2025

7:45 am  Registration & Coffee Service  National Ballroom Foyer

8:05 am  Welcome & Opening Comments  National Ballroom

• Stuart Vogt, Chairman, IADC Tax Committee; VP Corporate Tax, Transocean Ltd.
• Joe Lillis, Vice President of Policy, IADC

8:15 am  US & Canada Tax Update: Bret Oliver, Partner US Energy Leader, PwC
In the rapidly evolving energy sector, staying ahead of tax developments is crucial for drilling contractors. Our presentation will highlight the latest tax updates impacting the energy industry in the U.S. and Canada. We will explore significant changes in both the U.S. and Canadian tax landscapes, focusing on how these changes affect your businesses. The presentation will encompass the U.S. policy outlook on tax and tariffs, as well as Canadian initiatives aimed at economic recovery and environmental sustainability. We will also discuss the implications of the OECD’s Pillar II and the latest responses from both Canada and the U.S. Join us to gain valuable insights for navigating the evolving tax terrain and ensuring compliance in this dynamic environment.

9:05 am  ASC740 Guidance Update: Jenna Summer, Partner Washington National Tax Accounting for Income Tax, Hillary Swallen, Partner KPMG Houston Business Tax Services, KPMG
This session will include various items of relevance, but with a specific focus on the updated financial disclosure requirements under ASU 2023-09, effective for public companies in 10-K disclosures for 2025 and updates to quarterly disclosures being required in 2026 (for public calendar year filers).  Will also include a discussion of presentation items relevant to structures common in the drilling industry.  

9:55 am  Coffee Break

10:25 am  International Transfer Pricing Trends & Global Developments: Lauren Dangelmayr, Transfer Pricing Principal, PWC, Gene Tien, Principal Economist, Baker McKenzie, Jarrett Cosyns, Transfer Pricing Senior Manager, Anjit Bajwa, Transfer Pricing Principal, KPMG
This session will cover proposed and potential actions from the Trump administration and its subsequent implications for the industry and interaction with global rules. We will also cover global transfer pricing controversy trends and readiness with an emphasis on new sources of value creation within multinationals.

11:40 am Key Tax Developments for the Drilling Industry in West Africa: Faith Omekaodinma, Tax Director, PwC, Gilles de Vignemont, Partner, Vignemont Africa & Partners
Highlight of the latest tax updates impacting the drilling industry in West Africa. We will explore significant changes in Cameroon, Gabon, Congo, Ivory Coast and Nigeria, focusing on how these changes may affect your businesses. The session will be interactive and will include time for Q&A. Join us to gain valuable insights for navigating the evolving tax terrain and ensuring compliance in this dynamic environment. 

12:10 pm  Luncheon

US Foreign Tax Credits: Where Are We Now & Where Are We Going?: Brad LaBonte, Partner, McDermott Will & Emery
Recent developments in the US foreign tax credit rules are far-reaching but also come with practical applications for taxpayers. Gain insights on the creditability of foreign taxes, including Pillar Two taxes, foreign tax credit impacts of the proposed PTEP regulations, and recent notable case law.

1:30 pm  Pillar Two Update: Leslie Coye, International Tax Senior Manager, Brian Ong, International Tax Senior Manager, Deloitte
Preparing for the upcoming Pillar Two compliance deadline including best practices to implement an optimal approach to complete global filings. Also considerations from the Administrative Guidance released in January 2025 that impact the GloBE Information Return (GIR) requirements and other items impacting the drilling community.

2:20 pm  Brazilian Tax Reform and its impacts on Drilling Activities: Carolina Bottino, Tax Partner, Ivan Tauil, Tax Partner, Eduardo Telles, Tax Partner, Mayer Brown
In 2023 the National Congress approved, and the President of the Republic enacted, the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on consumption. The Constitutional Amendment requires that the Executive Branch present all bills to regulate the Tax Reform to the National Congress within 180 days after its enactment. On January, 16, 2025 Brazil’s president sanctioned Complementary Law No. 214/2025, which establishes the Tax and Contribution on Goods and Services (“IBS” and “CBS”), as well as the Selective Tax (IS). This panel intends to present an overview of this new regulation and its impacts for the drilling activity in 2026, when it becomes effective.

3:10 pm  Coffee Break

3:30 pm  A Brave New World: The Latest Tax Controversies: Rob Morris, Partner, Norton Rose Fulbright
Discussion of the complexities of current and emerging tax controversies, emphasizing key topics such as the IRS’s enforcement priorities, the IRS’s and courts’ evolving approaches to economic substance issues, transfer pricing, and other high-profile cases.

4:20 pm  EU Pillar Two Considerations in Relation to Debt Financing & Debt Restructurings: Miklos Santa, Partner Tax Services, Alexandre Pouchard, Partner/Principal, Richard Kocsis, EY
A brief overview on the latest developments / updates on Pillar 2 implementation in the EU focusing on the most relevant jurisdictions for drillers. Then cover the latest trends how drillers can navigate the challenges / issues triggered by Pillar 2 in the most relevant jurisdictions with a special focus on debt financing and debt restructurings. Lastly we briefly address the main considerations related to BBC and holding structures as well concerning the relevant EU jurisdictions.

5:00 pm  Welcoming Reception Sponsored by Norton Rose Fulbright National Ballroom