Tax Notes International Person Of The Year: Grace Perez-Navarro — A Champion Of Transparency And Inclusion

Grace Perez-Navarro’s career at the OECD began unexpectedly — as many life-changing events do — with a quick, off-the-cuff decision she made on an otherwise routine day in the early 1990s.

On that day, Perez-Navarro had settled into what she thought would be a long-haul career handling international tax matters at the IRS’s Chief Counsel office. She had risen through the ranks to become a special counsel, in charge of negotiating tax information exchange agreements, overseeing litigation, and coordinating guidance to the IRS’s field offices.

Not only was it work she enjoyed, but it was work she had actively pursued. When Perez-Navarro joined the IRS early in her career, she had hoped to handle international tax matters in Washington, D.C. But as a young lawyer, she didn’t have much say and the IRS posted her to Houston, Texas. She took it in stride, waiting for an opportunity to transfer until a chance meeting finally righted her path.

During a first-year training course, she asked the instructor a question that he could not answer. “It was not to be clever; it was an issue relating to one of my cases, and I just didn’t know what to do,” she said. “From then, I think he thought I was smart,” she laughed.

That instructor happened to be Mike Patton. Shortly after the training, the IRS tapped Patton to head a new international tax branch in Washington, and to Perez-Navarro’s fortune, Patton was looking for a few good attorneys. He called to ask whether she would be interested in joining, and she happily seized the opportunity.

So on a warm day in 1992, Perez-Navarro stepped out of her Washington office for a rare lunch with a friend, thinking of nothing more than enjoying the afternoon. She returned to IRS headquarters surprised to learn that her colleagues were frantically looking for her.

It turned out that her boss — then-Assistant Chief Counsel John Lyons — urgently needed to speak with her. But by the time she returned to the office, he was already occupied with a meeting. “OK,” she responded. “Just tell him I’m back in my office.”

“My colleagues said, ‘No, no, no. You have to get him out of that meeting,’” Perez-Navarro said.

She quickly did so, apprehensive that something had gone wrong. Instead, she was surprised to see Lyons, a former U.S. Marine and Vietnam War veteran — “a big, burly Boston Irishman,” as she described him — rush out dramatically.

He asked her right then and there in the hallway of the IRS, “How would you like to go to the OECD and help them revise the transfer pricing guidelines? In Paris?”

An opportunity to live in Paris? That’s certainly exciting for many people. But why the great excitement about revising the OECD transfer pricing guidelines?

The background is that a lot was at stake. The United States was just changing its transfer pricing rules to include profit methods, which was a big shift because no other country was using them at the time. Meanwhile, the OECD had not revised its transfer pricing guidelines since 1979, and the U.S. shift prompted an update, she explained to Tax Notes.

Perez-Navarro asked Lyons how much time she had to think about it. He told her 15 minutes. “I immediately said, ‘OK, I’ll do it.’ Because I thought, ‘One minute, 15 minutes — what’s the difference?’” That quick decision ultimately changed her life and career because nearly 30 years later, she is now director of the OECD’s Centre for Tax Policy and Administration (CTPA).

In 1993, a few months after that hallway meeting, she went to Paris on a one-year secondment to launch the modification of the OECD guidelines — a massive task. However, there was an even bigger issue that she had been eyeing at that stage of her career: bank secrecy.

From the 1970s through the 1990s, regulators around the world had their backs up against the wall as money laundering proliferated rapidly. In response, some of the best-known anti-money-laundering laws and programs emerged. In the United States, the Bank Secrecy Act and Financial Crimes Enforcement Network launched during this era. The Financial Action Task Force (FATF), an international anti-money-laundering organization, was also founded. But as regulators tried to close in on illicit activity, bad actors evolved their strategies to stay one step ahead. Meanwhile, so-called secrecy jurisdictions were loath to change their economies.

One of the most infamous examples during that period was the collapse of the Luxembourg-registered Bank of Credit and Commerce International. In 1991 it was the seventh-largest private bank in the world, operating in nearly 80 countries.

It operated a criminal enterprise in plain sight, routing billions of dollars from drug kingpins and dictators through a network of tax havens. Eventually the bank collapsed under the weight of massive fraud, taking with it billions of dollars in illicit money and also decimating savings of honest depositors.

In Switzerland, everyday citizens were hesitant to give up their country’s culture of bank secrecy. In 1984 a national referendum to give tax authorities access to bank records spectacularly failed, with 73% of voters opposing the idea.

So when Jeffrey Owens, then the head of the OECD Fiscal Affairs Division, asked Perez-Navarro, at the end of her secondment, what the OECD should be addressing, her answer came easily: bank secrecy.

“I had a lot of calls from the field offices when I was working in Mike’s branch: auditors saying, ‘We need information from Switzerland but can’t get it.’ And eventually the auditors stopped making requests to places like Switzerland because they knew they couldn’t get the information because of the bank secrecy rules. Then, when treaty negotiators would speak to the Swiss and say, ‘We need this information,’ the Swiss would respond: ‘Well, we don’t get any requests.’ But the auditors weren’t asking anymore because they were never getting anything.”

Perez-Navarro returned to the IRS, thinking little of the conversation. But Owens hadn’t forgotten her advice, nor had he forgotten how impressed he had been by her command of the transfer pricing revisions. Three years later, he called her out of the blue with a job proposition.

“I saw the potential, to have somebody with her technical ability who could combine that with good political judgment and with the energy to get things done. She’s a mover,” Owens told Tax Notes. “And I felt it would be great to get her back.”

During that call Owens gave Perez-Navarro an offer that not only set her career in a new direction, but also changed the entire trajectory of the OECD’s tax work. Would she be interested in returning to the OECD Fiscal Affairs Division to lead the group’s work on bank secrecy and exchange of information?

An Act of Tax War

In 1997, the year Perez-Navarro left the IRS to work with Owens, the global tax system seemed to be careening down a dangerous path. At least it appeared to be in the eyes of G-7 finance ministers. They recognized that governments are free to structure their taxes as low as they want as a strategy to attract investment or meet other policy goals.

But the G-7 worried that some countries were taking things too far and feared — rightly or wrongly — that tax competition was pulling countries into a race to the bottom.

The EU took matters into its own hands in 1997 when European finance ministers created a code of conduct on business taxation, promising that they wouldn’t engage in below-the-belt tax competition. The OECD closely followed with a 1998 report on harmful tax competition laying out four criteria of tax havens.

They included countries that have low or zero effective tax rates and do not effectively exchange information with others. The report also described features of harmful preferential regimes and measures that countries could take to counteract harmful tax competition.

Lastly, it established that the OECD would engage with nonmember countries adversely affected by harmful tax practices. The G-7 liked what it heard and decided to support the OECD’s work.

That report also established the OECD’s Forum on Harmful Tax Practices and called on the group to create a list of tax havens within one year, based on the four criteria. OECD members’ underlying assumption was that tax havens would not want to change, she explained. As such, the list was meant to help countries coordinate their antiabuse measures. This was a first for OECD members.

But according to Perez-Navarro, they deemed it important to address the tax haven issue because they were concerned that the harmful tax practices they were targeting would simply shift from the OECD area to other jurisdictions. This didn’t go over very well with the tax haven jurisdictions, she said.

“As soon as these jurisdictions were contacted to see if they met the criteria, major political alarm bells went off, and that was not a pretty moment,” she recalled.

It quickly became clear there was a mismatch in the dialogue between OECD members and the low-tax jurisdictions. In the low-tax jurisdictions, the debate ascended to the highest political levels because their economies depended on the types of activity that OECD members found harmful.

Meanwhile, the OECD was still engaging at a technical level. Simply put, OECD members failed to anticipate how the jurisdictions they were targeting would respond, she said.

“You had technical people looking at this issue and saying, ‘We don’t expect these jurisdictions to change. So how do we protect our tax bases?’” she explained. From that perspective, the OECD didn’t see the exercise as naming and shaming, as others came to accuse the organization of doing, she said.

However, the OECD went to great lengths to make the listing process an objective one, she said. Ultimately, many did express a willingness to change, which made the OECD alter its approach, she said.

“We fundamentally changed the project, and we brought those jurisdictions willing to change to the table,” she said. “We started a dialogue and provided a process through which they could commit to implement the transparency standards we had set and made it more a more cooperative, collaborative endeavor, which included participation in the Global Forum on Taxation. So we went from calling jurisdictions ‘tax havens’ to distinguishing between ‘cooperative and uncooperative jurisdictions.’”

“That was a really critical moment, and the OECD learned a lot from it,” she said.

Owens also said it marked a critical shift in the OECD’s tax work. “Over the years, particularly in the 1990s, she worked very closely with me to extend the agenda. The vision I think the both of us had was that the Committee on Fiscal Affairs should become a one-stop shop for tax policy makers and tax industry. If there’s an issue, whether it’s on tax administration, whether it’s on consumption taxes, whether it’s on tax policy, they should be coming to resolve this issue at the OECD,” Owens said.

“It was invariably from having somebody, Grace, who had a vision and the capacity to implement that,” said Owens, who shortly thereafter promoted Perez-Navarro to head the OECD’s International Cooperation and Tax Competition Division.

We Have Swine in Our Forest

Fast forward to April 2009 and that year’s G-20 meeting in London. Then-OECD Secretary General Ángel Gurría directed the OECD to do something very unexpected and very direct, at least by OECD standards: It announced a three-tiered tax haven white list, gray list, and blacklist.

“It was probably one of the hardest decisions that [Gurría] ever made. But he made it,” Owens said. “And because of the technical work that the team including Grace had done, we were sort of ready to run with that.”

In the shadow of the 2008 financial crisis, G-20 leaders had issued a statement declaring open season on “non-cooperative jurisdictions,” promising to deploy sanctions against countries whose tax regimes posed a threat to their own economies. In that statement, based on the OECD’s lists, the G-20 famously issued a declaration and a challenge: “The era of banking secrecy is over.”

Unsurprisingly, the lists didn’t go over well with the OECD’s own membership. Austria, Belgium, Switzerland, and Luxembourg landed on a gray list and immediately fought back. Jean-Claude Juncker, who at the time was Luxembourg’s prime minister and finance minister, slammed the list as a “rush job” and “incomprehensible.” And it certainly didn’t go over very well with non-OECD countries.

“The reality was it was a painful process, it was not very pleasant. But I think at that point in time it was necessary, and it worked,” Owens said. “I’m not particularly keen on blacklists but I think without that threat of blacklisting, and the gray list or the white list, we wouldn’t be where we are today.”

“It changed the dynamics, and it ultimately forced countries, including the gray-listed four OECD member countries, to fundamentally change their approach to bank secrecy,” he said.

It also changed the OECD. Up until that point, the OECD’s bread and butter tax work was mostly technical and insular — transfer pricing, tax treaties, and some exchange of information work. It was nothing that would draw international headlines or suggest that the OECD had a global, wide-sweeping influence over international tax policy.

For many years, the OECD’s was the only voice pushing against bank secrecy, Perez-Navarro said, and it attracted few friends. It seemed like everyone had a problem with the work, starting right at ground zero within the OECD membership.

“I remember one meeting where we were trying to make progress on the issue, but we had countries within the OECD membership with very strict bank secrecy who were not interested in changing,” she said. The discussion reached an impasse, frustrating some members, she recalled.

“At one point one of the delegates said something like, ‘Well, we know we have swine in our own forest.’ Diplomacy was out the door,” she said.

Financial institutions weren’t very diplomatic about the idea either. Neither was civil society, but for different reasons. When civil society decided to campaign against bank secrecy, Perez-Navarro said she was excited to have another voice that could counteract many of the criticisms the OECD was hearing at the time.

“‘It’s too burdensome; the information will be misused to kidnap people, to extort them.’ We heard this from the financial sector and conservative groups all the time,” she said.

“So it was good that we had this other voice supporting our efforts although they didn’t think we were going far enough,” she said. “They wanted countries to automatically exchange banking information from the outset but we would never have gotten agreement on that among OECD members in 2000, when we produced the first bank secrecy report, or even after the Liechtenstein scandal of 2008, which revealed the extent of tax evasion through secret accounts, or at the time of the financial crisis in 2009,” she said.

“The global financial crisis brought political attention on the issue of bank secrecy,” she said. “That really changed the whole ballgame.”

When the G-20 threw down its gauntlet, it made it clear that the OECD would be an integral partner. Much of the preparatory work that Perez-Navarro and her team had done on bank secrecy and exchange of information suddenly came into play in a real way, Owens said.

“It was all about having the right ideas at the right time,” he said.

But in the immediate moment, the bigger question was, how would the OECD, now with the full political will of the G-20, turn that preparation into substance and eradicate bank secrecy?

A New Normal

Just a few months later, the OECD offered a solution. It would expand an existing transparency group — the Global Forum on Taxation — from a forum of OECD members and cooperative jurisdictions into a true global and inclusive forum open to all countries, who would participate on an equal footing.

This new Global Forum on Transparency and Exchange of Information for Tax Purposes would be a separate, OECD-hosted body open to any countries and jurisdictions that committed to implement international standards on tax transparency and exchange of information. Members would peer review each other on these standards.

Opening the Global Forum to non-OECD countries, particularly developing countries, and doing so on an equal footing was an extremely huge shift, something that hadn’t really been done in the OECD before, Perez-Navarro said.

It’s a job to which Owens gave her a lot of credit, noting that it was personally important to Perez-Navarro, given her family’s roots in Latin America.

By that time Perez-Navarro had been promoted again, to deputy director of the CTPA, and she collected data to make her case, speaking to other divisions of the OECD and the FATF that already did peer reviews to figure out what it took, because the CTPA had never done that before.

“But then, I had to sell this to our members. I remember we had a bureau meeting, and I explained to the group what I had done to calculate what the budget would be, and it was high. And they said, ‘We see what you’re saying, we understand. But politically we cannot have a budget higher than the FATF’s.’”

Why? Because money laundering is perceived as a higher priority than tax evasion, they told her.

“The biggest challenge has always been that we have much more work to do than resources. We operate, it seems, on this approach of ‘build it and they will come.’ So we’re always just so maxed out in terms of what we’re trying to do,” she said. “But the one thing I was very keen on when we revamped the Global Forum, which is separately funded by its members, was that this would be a fully funded program.”

The OECD’s position as the world’s leading multilateral tax policymaker is so entrenched that it is sometimes easy to forget that this status is relatively young. The OECD made this transformation just 13 years ago, and it started with the restructured and expanded Global Forum. From there, it has expanded into work on base erosion and profit shifting and other issues.

Perez-Navarro was integral to that expansion, much of which occurred under the leadership of Pascal Saint-Amans, who was director of the CTPA from February 2012 until October 2022.

“Grace and I literally shared all responsibilities during my tenure as a director. We worked very closely, on a daily basis, to advance the projects, recruit the team, and raise funds,” he told Tax Notes.

“Now it’s become part of the new normal,” Perez-Navarro said. “We created the inclusive framework on BEPS, and it wasn’t a big deal; our members understand the importance of inclusivity. Right now, we’re setting up the inclusive forum on carbon mitigation approaches.”

The Global Forum is the world’s largest multilateral tax body, with 165 members, and the inclusive framework on BEPS closely follows with 141 members. Although the sizes are similar, some scrutinize the inclusive framework’s inclusivity in ways that are not applied to the Global Forum. When asked about that, Perez-Navarro mused that perceptions of the two groups may differ because of their underlying goals.

“The Global Forum is about helping tax administrations administer their domestic tax laws. That’s of relevance to everybody. The inclusive framework on BEPS is focused on the taxation of multinational companies, which may not have the same priority for all countries, including the least developed, which may have other more pressing tax issues. But the inclusive framework is open to all,” she said.

Then again, the Global Forum has endured its own pressures over the years, from those who initially rejected widespread automatic exchange of information as an unrealistic pipe dream to those who argued the Global Forum wasn’t moving fast enough.

“Back in the day when civil society said we needed to do more on bank secrecy, they were right about the importance of automatic exchange of information,” Perez-Navarro said. “But if we hadn’t started with exchange of information on request, we never would have gotten to automatic exchange. And the reality is you need both.”

“With automatic exchange, you’re getting one piece of information, but then you need to look further. If that information came from abroad, the other information you need will also be abroad, and you can make that request,” she said.

Reflecting on Missed Chances

In the background of this work on bank secrecy and harmful tax practices, Perez-Navarro was closely monitoring another issue: the taxation of electronic commerce.

In 1998 the OECD saw the direction the economic winds were blowing, and they were blowing toward the digital economy. In response, the OECD launched a major cross-border e-commerce tax reform project and devised a set of guiding tax principles to apply to e-commerce — the Ottawa Taxation Framework Conditions.

Although that work was helpful, Perez-Navarro thinks the OECD missed an opportunity to do more at that time.

“I think we were too quick to accept the view that the existing rules still worked. We should have started to think back then about how the internet, e-commerce, digitalization might change the global economy and what that would mean for tax,” she said.

By the time the BEPS project launched in 2013, digitalization, the internet, and e-commerce had dramatically changed the world, but tax rules had not kept apace and there was growing frustration among some countries about the outcomes.

“If you can deal with an issue before it becomes a serious, pervasive one, you may be able to have a better conversation with countries about how to solve it, before they get stuck in their positions,” she said.

“Rather, we work on the issues of the day,” she said.

A Second Chance at Digital Reform

This takes us to the OECD’s current international tax reform project and pillars 1 and 2.

Perez-Navarro, who became director of the CTPA in November, said her foremost priority is finalizing pillars 1 and 2. She told Tax Notes that the United States is fully engaged in negotiations and working hard to try to reach an agreement with the other inclusive framework members.

“An agreement is needed with the U.S. on board to deliver pillar 1 because many of the multinationals concerned are headquartered in the U.S. If it doesn’t participate, then countries will think about what they’re going to do,” she said. Countries have been waiting for a solution for nearly 10 years, she noted, and they may not be able to wait much longer.

“A lot of countries have said they are getting pressure from their parliaments to enact unilateral measures because this is taking so long and they see other countries have them,” Perez-Navarro said. She cited, as an example, Colombia, which recently included a significant economic presence provision in a wide-sweeping tax reform package.

“From the Colombians’ perspective, they saw this as insurance in case the U.S. doesn’t adopt pillar 1 — then they at least have something in their laws. You can’t do tax reform every five minutes, so they placed it there now as a safety net,” Perez-Navarro said.

“I think the alternative scenario is pretty easy to see. If there is no agreement on pillar 1, we will be back to the chaos that uncoordinated unilateral measures will create,” she added. “So that’s where the U.S., like other inclusive framework members, will have to weigh the pros and cons of pillar 1 as opposed to unilateral measures.”

Also, the global community is clamoring for more revenue information on both pillars. They want to know: If they are going to implement these complex provisions, just how much revenue can they expect to gain? The OECD released an aggregated economic impact assessment in October 2020, and it will issue an updated assessment in mid-January.

Perez-Navarro’s other priority as director is launching the inclusive forum on carbon mitigation approaches, which will have its first meeting in February 2023. Perez-Navarro noted that the OECD is trying to complement the efforts of the U.N., which is leading global climate change policy with things like the Paris Agreement and COP27.

“The purpose of this initiative is basically an evidence-gathering exercise and a way to provide a forum for discussing different approaches to reducing greenhouse gas emissions, including both pricing and non-pricing mechanisms, and their effectiveness,” she said. “What we’re trying to do is to support the world’s overall objective to reduce greenhouse gas, to get to net-zero emissions.”

The Road Ahead

This is a particularly woman-forward era for the CTPA, with Perez-Navarro at the organization’s head, and her colleague Zayda Manatta at the head of the Global Forum secretariat. Both co-chairs of the inclusive forum on BEPS are women: Fabrizia Lapecorella and Marlene Nembhard-Parker.

It’s certainly not the OECD that Perez-Navarro walked into in 1993 when she was one of maybe two or three professional women in the entire fiscal affairs division and a male colleague from another division screamed at her for the terrible, unforgivable offense of allegedly using the wrong printer.

“I’m sure he would not have yelled at me if he’d thought I was something more than just an assistant,” she said. “I went back and I told Jeff that my government is paying lot of money for me to be here, and I will not be treated this way.”

Gender inclusion, specifically the intersection of tax and gender policy, is an area Perez-Navarro has long championed. The OECD has been devoting increased attention to this as well, and Perez-Navarro hopes that the OECD will be able to push more resources in that direction in the coming years. Saint-Amans commended her for creating a foundation for that tax and gender work.

“Pitching it and making it a G-20 deliverable was her own initiative and her own success,” he said.

On the general topic of inclusivity, the OECD’s work has shown that large-scale tax multilateralism is attainable, even though it might be strained or challenged at times. But it has its critics, and Perez-Navarro chafed at ongoing public criticism that the OECD is not an inclusive tax body.

“I feel like we’re forever innovating in this space to make sure all countries can participate effectively,” she said. “Because the work on the pillars is moving so fast, we’ve established regional virtual meetings to explain what’s going on to allow countries in smaller groups to ask the questions they want to ask in a safe space with their peers, their regional peers. We also provide bilateral support and pre-meetings for developing countries.”

“We also partner with regional groups like the African Tax Administration Forum and are working very closely with them to understand their members’ concerns, figure out how we can respond to them, and do everything we can to help those countries participate in a meaningful way,” Perez-Navarro added.

When asked how she thinks the OECD can continue its multilateral momentum, Perez-Navarro said that the processes are already in place, and they just need to keep operating.

“One of the important aspects of all of this is supporting countries, particularly developing countries, in their understanding of what is at stake, what’s been proposed, and supporting them through their decision-making,” she said. Programs such as Tax Inspectors Without Borders, a joint effort with the United Nations Development Program that helps developing countries with tax audits, give her hope for the future of tax multilateralism.

“For every dollar spent, there’s a return in tax revenue of $100. I wasn’t the one who developed it, but I am very proud of it, and we’re looking to expand it into other areas,” she said.

“We’ve moved into the criminal tax area because those are some of the most challenging cases to pursue and prosecute as they usually tend to be cross-border. It’s really important to show your citizens, especially in developing countries, that you are not letting people get away with tax evasion. It’s really important to address that end of the spectrum, even if dealing with multinationals and high net wealth taxpayers is probably a better value in terms of return,” she said.

“Those who are committing fraud or evasion undermine trust in the system, and undermine overall voluntary compliance,” she explained.

In the present day, it is well understood that tax evasion and money laundering often work in tandem. Yet that wasn’t always the case.

Recall that Perez-Navarro was once told that money laundering is a higher priority than tax evasion. But over the years, she actively pursued a relationship with the FATF, because she knew that when tax evasion happens, money laundering quickly follows.

“The first contact she had with the FATF, they were almost like ‘What is this character Grace coming to talk to us about? Why does the tax person want to get involved with us?’” Owens said. Eventually, the FATF came to see things the way she did, and in 2012, declared tax crimes as a predicate offense to money laundering.

“That doesn’t sound like much. But believe me, that was very much a revolution,” Owens said.

The OECD’s work on tax crimes routinely gets lost amidst the political theater of its work on BEPS and tax havens, but it’s some of the work that Perez-Navarro is most proud of. And in 2013 the organization established an OECD Academy for Tax and Financial Crime Investigation in Ostia, Italy, to provide training for officials hailing from countries where that education simply isn’t available. Over the years, the academy has expanded and now runs regional centers in Africa, Asia-Pacific, and Latin America.

“When you look at a huge tax administration like the IRS, they have a Criminal Investigation Division where they do training, and the U.S. Justice Department does training,” she said. “But in smaller countries, they barely have a criminal investigation department, and they don’t do training.”

A Tax Evolution

The word “revolution” is often used to describe the OECD’s tax work, but Perez-Navarro has a different take on the group’s history.

“I always say, ‘The work we have done has been evolutionary, not revolutionary,’” she added. “A lot of people think it’s a revolution, but we could not have done the work that we were able to achieve through the Global Forum if we hadn’t previously done the basic work on bank secrecy and harmful tax practices. Without the Global Forum, I don’t think we could have established the inclusive framework on BEPS. Without the BEPS project, we wouldn’t have pillars 1 and 2. So it’s evolutionary.”

Either way you describe it, the OECD’s work has significantly changed the international tax landscape and the way that the world discusses international tax policymaking.

“In the tax world, when people ask you, ‘What do you do?’ and you say, ‘Well, I make a lot of money,’ that’s easy in the tax world,” Owens said. “If you can say ‘I changed the world, just by a small amount, just by a little bit,’ that’s rarer. And Grace can say that because of the work she did on tax crimes, because of the work she did on tax havens and exchange of information. It’s a proud legacy that she leaves behind,” Owens said.

That legacy, extending back to the harmful tax practices project, allowed her to be the most experienced person in the team, with a unique historical memory, Saint-Amans added. “She is an open library [and] extremely well organized. She has always been key to keeping projects on track.”

And Perez-Navarro is on the cusp of her own evolution — she will retire from the CTPA in March. What will Perez-Navarro, who has had one of the most storied and interesting careers at the very center of international tax, do next?

“Stay tuned,” she said.