What to do today to prepare for Pillar Two

Clifton Davis

Clifton leads Deloitte’s International Tax Clients and Markets and Deloitte’s International Tax Services in Chicago, Milwaukee, and St. Louis. He has more than 20 years of experience serving clients in a variety of corporate and international tax issues, including international expansion, structuring, acquisitions, earnings repatriation, and foreign tax credit planning. Clifton is also the global lead tax partner for many of his clients providing services across multiple disciplines and countries. He provides consulting and compliance services to Fortune 500 publicly traded corporations, as well as large closely-held enterprises.

Bob Stack

Bob advises the US companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation and Development (OECD). Bob joined Deloitte Tax from the US Department of the Treasury (Treasury), where he was the deputy assistant secretary for international tax affairs in the Office of Tax Policy. While there, he worked directly with the assistant secretary of tax policy and the international tax counsel in developing and implementing all aspects of US international tax policy, including treaties, regulations, and legislative proposals. He also was the official representative of the Obama administration for international tax policy and represented the US government at the OECD where he was involved in all aspects of the Base Erosion and Profit Shifting initiative. Prior to joining Treasury, Bob had more than 25 years of experience in international tax matters, representing both corporations and individuals. Bob is a member of the executive committee of the US Branch of the International Fiscal Association (IFA) and a frequent speaker at IFA events worldwide. He a member of the advisory committee for the Annual Institute on Current Issues in International Tax at The George Washington University School of Law. He is a frequent speaker at events sponsored by such organizations as the Tax Executives Institute, the International Bar Association, American Bar Association Tax Section, and Irish Tax Institute. He presented the Twenty-Second Tillinghast Lecture on International Taxation at the New York University School of Law. Bob earned his Bachelor of Arts in English education from State University of New York at Albany and his Master of Arts in French language and literature from New York University. He went on to obtain his Master of Science in foreign service from Georgetown University and a Juris Doctor from Georgetown University Law Center, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.

Chad Hungerford

Chad is a partner in Deloitte Tax LLP’s international tax practice and is based out of San Jose. He has more than 18 years of experience advising US based multinational companies on the tax planning, tax accounting, and tax reporting obligations associated with their global footprint. Chad is a national resource for the taxation of the cloud, the use of technology by tax departments, and international accounting for income taxes. Chad is Deloitte’s US Pillar Two leader, IT ASC 740 leader, and Silicon Valley IT practice leader. In addition to his leadership roles, Chad’s experience includes assisting clients with structuring acquisitions and divestitures, developing and executing plans for post-merger integration of acquired companies, and assisting companies as they restructure their global supply chains. Chad received a Bachelor of Science in Accounting and a Master of Science in Accounting from Brigham Young University. He is a licensed Certified Public Accountant in Washington and California and is a member of the American Institute of Certified Public Accountants.