April 23, 2025 | Pillar 2 at a Crossroads: U.S. Policy and What Comes Next

The future of the OECD’s pillar 2 project and U.S. involvement remains a focal point of international tax discussions. As the global minimum tax continues to gain traction across jurisdictions, questions emerge about the direction of U.S. policy under the new administration. Can pillar 2 function effectively without U.S. participation? Are there possible compromises between the OECD and U.S. positions? How will companies be affected in a fragmented system?  

Tax Analysts is offering this episode of Taxing Issues as a free service to the public, and all attendees can receive CPE credits. To do so, you must register for the webcast before it starts and log in no later than the scheduled start time. You also must request CPE credits before each webcast, and you must answer the polling questions that will be asked throughout the event. 

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ABOUT THE SPEAKERS

Cara Griffith
President and CEO, Tax Analysts

As the moderator for our Taxing Issues webinars, Cara objectively analyzes issues and asks probing questions that challenge panelists to explain and defend their positions.

When she’s not moderating Taxing Issues webinars, Cara provides strategic oversight for Tax Analysts. She has led efforts to improve the Tax Notes suite of products and to aggressively pursue transparency in the administration of tax systems. Previously, Cara managed the editorial department, including the flagship daily news publications and weekly magazines. She has written for a broad range of tax policy publications, including Tax Notes State, The Tax Adviser, The Hedge Fund Law Report, and The Hill. She regularly speaks at tax conferences and other events, discussing a variety of technical tax issues as well as the need for transparency in tax administration.

Cara has a BA in political science and a BA in international studies from the University of Evansville and a JD from the George Washington University Law School.

Pat Brown
Partner and co-leader of PwC's Washington National Tax Services Practice

Pat Brown is a partner in and co-leader of PwC’s Washington National Tax Services practice. He advises clients on all aspects of international and domestic policy. Previously, Brown was vice president and counsel of tax for GE Power and GE Renewable Energy and a GE corporate officer. He was also the director of tax policy for GE. 

Before that, Brown was a senior international tax counsel for GE corporate and GE Capital. He had responsibility for the company’s overall foreign tax credit position and was a principal technical adviser to the tax director of GE. 

Brown served as Treasury attorney-adviser and associate international tax counsel from 1998 to 2002. Before that, he was an associate at Sullivan & Cromwell in New York. 

Brown received a BS in mechanical engineering from the University of Virginia and a JD from Georgetown University. 

Joachim Englisch
Chair for tax and public law at Münster University

Joachim Englisch is Chair for tax and public law at Münster University in Germany. He is also a visiting professor in several LLM programs. His research focuses on international and European tax law, covering both direct and indirect taxation.  

Englisch serves as an adviser to the OECD and the European Commission and has advised national governments, nongovernmental organizations, and members of Parliament. He is widely published.

Mindy Herzfeld
Professor at the University of Florida Levin College of Law and counsel for Potomac Law Group

Mindy Herzfeld is of counsel for the Taxation and Mergers and Acquisitions Practices at the Washington, DC office of Potomac Law.  

Ms. Herzfeld specializes in cross-border taxation, and has experience advising both public and private clients in complex international acquisitions, dispositions, and joint ventures. She also regularly consults with clients on international tax policy developments. 

Ms. Herzfeld is a Professor of Tax Practice at the University of Florida, Frederic G. Levin College of Law, where she teaches courses in tax policy and international taxation for LL.M students. Since 2014, she has been a Contributing Editor to Tax Notes International, a weekly magazine on tax developments published by Tax Analysts. In that capacity, she has written over 250 articles on international tax policy developments and cross-border transactions and has also written extensively on U.S. tax reform efforts.  She is the author of the bestselling introduction to the field, International Taxation in a Nutshell, 12th ed. (West 2020). 

 

Previously, Ms. Herzfeld worked at the national tax office and the New York office of a Big 4 accounting firm, where she provided transactional advice to U.S. and foreign multinational corporations, private equity funds, venture capital funds and individuals on a broad range of U.S. and cross-border tax issues.  She began her career in the New York office of a global law firm and has also worked as in-house tax counsel at a large automotive manufacturing company. 

Ms. Herzfeld received her J.D. from Yale Law School and her LL.M. from Georgetown University Law Center. 

Scott Levine
Former Treasury deputy assistant secretary for international tax affairs

Scott Levine was the Treasury deputy assistant secretary for international tax affairs through the end of the Biden administration, where he led the Treasury Office of Tax Policy’s work on international tax, including regulations, treaties, and pillars 1 and 2. 

Levine joined Treasury from Jones Day, where he was a tax partner in the firm’s Washington office advising clients on aspects of corporate and international tax matters. 

Before that, Levine was a senior manager in the KPMG National Tax Office, as well as an adjunct professor at George Mason University School of Law. 

Levine has been an adjunct professor of law at the Georgetown University Law Center in Washington and the International Tax Center at Leiden University in the Netherlands. He has frequently lectured and participated as a panelist at programs for the American Bar Association, D.C. Bar, Practicing Law Institute, International Fiscal Association, Tax Executives Institute, and Southern Federal Tax Institute. 

Levine is an active member of the ABA Section of Taxation.  He has been a member of the section’s council and its nominating committee and has chaired its Corporate Tax Committee. He was a two-term member of the D.C. Bar Tax Section’s Steering Committee and chair of its Corporate Tax Committee. Levine was chair of the D.C. Bar’s Annual Tax Reform Conference from its inception in 2017 through 2023 and will again chair the event in 2026. 

Sponsorship opportunities for Taxing Issues events and webinars are available.  Please click here for more information.