Women in tax roundtable: tax counsel and executives’ perspective on challenges, opportunities and solutions

Gloria María Gurbista
Mitrani Caballero, Buenos Aires
gloria.gurbista@mitranicabalero.com

Report on a session at the 17th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami

Wednesday 18 June 2025

Session Co-Chairs
Alice Abreu Temple University School of Law, Philadelphia
Raquel Novais Machado Meyer, São Paulo

Speakers
Marilyn Basallo Restaurant Brands International, Miami
Arielle Borsos Uber, Washington, DC
Maria Fernanda Campos Ford Latin America, São Paulo
Carolina Cintra J.P. Morgan Private Bank, Miami

This panel of women tax counsel and executives analysed the challenges and opportunities faced by in-house tax advisers in an environment characterised by constant regulatory changes, the emergence of artificial intelligence (AI) and the complexity of international reforms such as Pillar Two.

Challenges and opportunities over the past year and the actions taken in response

Maria Fernanda Campos stressed that the main challenge lies in adding value to the business. In this context, with the emergence of AI, Campos stressed that, as a leader, it is essential to understand how this tool can optimise both your own performance and that of your team. She emphasised the importance of identifying the most appropriate technological tools, and pointed out that the main contribution of technology is to generate reliable and timely data, which is essential for meeting regulatory requirements. She also shared the concern of work teams (especially older workers) in the face of increasing automation, and expressed her commitment to empowering people so that they have real opportunities to become familiar with automation systems and AI tools.

Arielle Borsos shared her recent experience joining Uber’s in-house tax team, having previously worked in the International Division of the Internal Revenue Service’s (IRS) Office of Chief Counsel. She stressed that the change meant moving from a ‘tax logic’ oriented to auditing and litigation in the public sector to a ‘business logic’ in the private sector. She highlighted the importance of understanding the company’s business model to add value in advice. Regarding the use of AI, she pointed out that, unlike her experience in government, at Uber there is a strong push to incorporate AI solutions into daily work. Borsos explained that AI is primarily used to streamline repetitive tasks but emphasised that it does not replace professional judgement. Borsos warned that the main risk is over-reliance on AI and losing the ability to think critically.

Carolina Cintra stressed that the main challenge in countries with constant legislative changes is to stay up to date, since clients expect immediate explanations when tax developments arise. She shared an experience related to the impact of tax news and the pressure from clients for immediate answers. Cintra highlighted the difficulty of anticipating and managing these expectations in environments as rapidly changing and dynamic as the current ones.

Marilyn Basallo also emphasised the challenges involved in the adoption of AI. She warned about the risk of relying excessively on these tools, stressing that they are a complement that enhances efficiency but does not replace the value of human work. Basallo exemplified the usefulness of AI in the context of experiencing high demand but having limited time.

Raquel Novais pointed out the advanced use of AI by the Brazilian tax authority and highlighted the high level of knowledge that it has about taxpayers thanks to technology. She mentioned that the quality of the work carried out by the Brazilian tax authority, now enhanced by AI, poses new challenges in tax litigation. She also highlighted the investment made by the Brazilian judiciary in technology and recognised that, although AI still makes errors, it is reasonable to expect that these will be overcome in the future – which will change professional practice.

Based on these comments, Alice Abreu put into consideration the complexity that will be involved in controverting information generated by AI in the tax field, given its high quality.

Campos shared her vision and pointed out that, in the future, the debates between the tax authorities and taxpayers will focus on interpretative issues, not on debates about facts.

Considering Novais’ comment about the investment of the Brazilian authorities in AI, Basallo contrasted it with the agility of response of the tax authorities in the US. She mentioned delays in refunds and notifications by the IRS, and suggested that greater adoption of AI by the tax authority could improve the efficiency of daily operations and the updating of tax information.

Borsos offered a different perspective. She stressed that the biggest challenge in her work lies in explaining the business model of technology companies (such as Uber) to the tax authorities, especially in relation to the nature of services and revenues. She pointed out that the main challenge is not the use of data by the authorities, but the clear explanation of how the business works, which impacts in the application of international and digital taxes.

As a conclusion to the first topic of the panel, Abreu proposed to comment on the challenges found in interacting with the ‘internal client’ as in-house tax advisers.

Borsos recounted her experience joining Uber and highlighted the importance of understanding the business beyond the legal aspects to provide real value in tax advice. Considering her previous work at the IRS, she spoke of a substantial change in her approach to the issues, going from an auditor’s perspective to that of a collaborator to obtain the result of the operation.

Basallo also highlighted the change in mentality when going from being an external adviser to in-house. In the latter scenario, she highlighted the importance of practicality and the viability of the proposed solutions. She stressed that she has multiple internal customers and considers it relevant to educate the different internal departments and maintain effective communication to anticipate and solve problems collaboratively.

Developments in domestic law or international law that affect practice

Discussing the panel’s second topic, Abreu proposed to examine how developments in domestic or international legislation (eg, Pillar Two) have affected the professional practice of the panellists, and how they provide advice in these scenarios.

Borsos highlighted that Pillar Two adds an additional layer of complexity to multinational operations. She explained that in a transaction it is necessary to consider multiple variables and circumstances, to which Pillar Two is now added. She acknowledged that its application may limit the possibility of carrying out certain operations from the US tax perspective.

Basallo complemented Borsos’ point from the perspective of financial accounting. She highlighted that, in the past, certain accounting entries to clean up balance sheets did not have a major impact on financial consolidation. However, with Pillar Two, even these moves can have unexpected tax consequences, such as generating additional revenue in jurisdictions that have implemented the reform that can lead to the obligation to pay additional taxes. Basallo emphasised the importance of educating everyone involved about how these changes affect financial statements and the need to be more careful with the information reported.

Campos pointed out that the implementation of Pillar Two was a tactical change that, by affecting everyone equally, facilitated the explanation to the parent company in the US. She also emphasised the difficulty of explaining to domestic and international interlocutors the impact of unusual legislative changes (‘unique animals’ such as the Impuesto PAIS applied by the Argentine tax authority) and mentioned the challenge of tax reform in Brazil, underscoring the enormous complexity of the Brazilian tax system and the promise of simplification that reforms bring. She highlighted her responsibility in adapting internal systems, managing communication and ensuring the sustainable implementation of changes.

Cintra referred to the emotional component in the management of her internal clients, considering the scope of her advice. She stressed that personal or family situations add a layer of complexity to communication and tax decision-making.

In conclusion, Abreu, given her previous experience as an external adviser and now working in the academic field, reflected on the difference between working with multiple clients and getting to know a single industry in-depth when being in-house. She acknowledged the value of deeply understanding the business, but brought into the panellists’ consideration the ‘dark side’ of internal management: the need to coordinate and execute the implementation of transactions and contracts, ensuring that they reflect operational reality.

Cintra responded that anticipating problems facilitates management, since it allows her to propose alternatives and adjust strategies according to the particularities of each case. She stressed the importance of knowing the operation in-depth to offer viable solutions adapted to the reality of each client.

Basallo added that, to face the challenges that Abreu mentioned, it is good practice to involve other departments from the beginning of a transaction or operation. This allows the workload to be distributed and ensures that all relevant areas (legal, accounting, treasury) are involved in the implementation, aligning the vision of the company and external advisers.

Borsos pointed out that, by working in-house, contracts and documents more faithfully reflect the real operations of the company, unlike external experience where sometimes documents are updated without a deep knowledge of the operation. She stressed the importance of the documentation adequately supporting the transactions carried out.

Finally, Campos pointed out the difficulty of quantifying the impact of certain tax changes and the pressure to offer accurate and rapid responses – acknowledging that the only certainty in the business environment is uncertainty.