The global tax system is undergoing significant changes as countries wrestle with questions about who should have the right to tax income, especially in the context of multinational corporations operating across multiple jurisdictions. At the core of the debate is the question of which jurisdiction has the most legitimate claim to tax a company’s profits and how this right is determined. As countries seek to balance sovereignty with fairness, the evolving landscape of international taxation is marked by both convergence and divergence. 

This episode will explore the core debate between tax jurisdiction and legitimacy, finding a potential compromise between current U.S. Tax Law and BEPS 2.0, and the implications for the digital economy and transfer pricing.

Disclaimer: The Financial Executives Edge provides informational content only and does not constitute financial, investment, legal, or career advice. The views expressed are those of the hosts and guests and do not reflect the views of The Financial Executives Networking Group or its affiliates. We make no guarantees about the reliability of the information presented. Listeners should consult a qualified professional before making financial or career decisions. The hosts and creators assume no liability for actions taken based on this content.

Andrew Silverman

Lead Transactional & Tax Policy Strategist at Bloomberg Intelligence

Senior tax policy and transactional analyst at Bloomberg Intelligence, a platform within Bloomberg Professional Services on the Bloomberg Terminal.

I have a broad tax, policy and transactional focus. I write about international and US federal and state tax change, the OECD BEPS initiative, tax controversy, transfer pricing and tax issues related to M&A and capital markets. I also cover M&A, IPOs and other corporate transitions.

I appear on Bloomberg Radio and TV to discuss tax issues, corporate actions and policy prognostication.

Chris Migliaccio

Partner - International Tax, M&A and Employee Retention Credit Leader at PKF O'Connor Davies, LLP

Experienced International Tax practitioner with a demonstrated history of working with both large multinational and startup businesses on tax planning and structuring. I have written extensively on International Tax issues relating to tax reform - making tax knowledge accessible is a passion. Additionally, I am a frequent speaker and moderator at various firm and industry programs on current tax issues. In practice, I manage the development and implementation of transactions, as well as complex compliance and audit projects. I have also taken on the role of being the firm's Employee Retention Credit leader. I'm the former host of the World of Tax podcast, covering timely important tax topics with other tax experts.

Ryan Bradford

Ryan Bradford is a Sourcing and Procurement executive, a transformational leader with 20+ years of experience, across multiple industries, including the iconic brands of The New York Times, Disney, and Farmers Insurance. Ryan is an industry expert, contributor, speaker, author, and volunteer on the Business Development Committee at The Financial Executives Journal. Ryan earned a BS and MBA from Pepperdine University, a Certificate in Dispute Resolution from the Straus Institute at Pepperdine Law School, and a CPSM from ISM.

Lynn Gargano

I am a Senior Financial Leader/ CFO and Strategic Business Partner with a strong, analytical, and entrepreneurial mindset. I specialize in breaking down silos and connecting data, teams and priorities, to create clear, actionable insights that drive results. With a strong knowledge in finance, strategy, and risk management, I focus on P&L management, using metrics to support growth, financial planning, and decision-making while identifying and mitigating risks.

My extensive background in financial services, particularly in Asset and Wealth Management, includes working with Investment Advisors and cross-functional teams across Product, Sales, Technology, and extended Global and Regional teams. My Big 4 public accounting experience has helped me build a comprehensive skill set in financial and management reporting, financial planning, strategic partnering, and finance transformation.

I have a consistent track record of progression and loyalty, having worked in both private and public global organizations. My experience also extends to having a seat at the table in Risk Management, Product, Executive Management and Board Committees.

I apply my extensive strategic business and financial skill set as an Advisory Board Member and Chairperson of the Business Development Committee, for the Financial Executives Networking Group (FENG), a 501(c)(3) nonprofit. In this role, I provide advice on business strategy, a sustainable business model, digital marketing, new services and content, strategic partnerships and thought leadership. Additionally, I serve as the Editor for the Financial Executives Journal, an online publication focused on industry insights, career growth, and professional development.

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