Bill Amon is a Partner at WTAS LLC in Los Angeles. Bill has over 30 years of experience in corporate and international taxation. He advises corporations, partnerships and limited liability companies on a broad variety of business and tax matters, including: Mergers and acquisitions planning and consultation; Restructuring planning; Accounting methods; Transfer pricing; International tax planning and consultation; Preparation or review of income tax provisions and analysis of uncertain tax positions; Preparation or review of corporate and other entity federal and state/local tax returns; Representation in tax examinations, including development of tax controversy strategies; Executive compensation plans; Intellectual property planning including high technology. Bill has extensive experience in serving clients in many industries, with an emphasis on high technology, media & entertainment, aerospace and healthcare. Bill has been recognized as one of the Top Tax Advisors in North America in 1998, 1999 and 2001 by the International Tax Review and by Euromoney Magazine for years 2003-2008. Bill earned his BS from the University of Santa Clara and his JD from the University of Santa Clara School of Law. Bill is a member of the American Institute of CPAs; California Society of CPAs; California Bar Association; Advisory Board Member, Santa Clara School of Law-International Law; Adjunct Professor of Tax, Golden Gate University’s Master’s Program; Member, Los Angeles International Tax Forum.
John Apuzzo is an International Tax Senior Manager located in the Costa Mesa / Los Angeles office of Deloitte Tax LLP, serving clients in the Western Region. He has over 16 years of international taxation experience. John has been part of an International Tax services group of another Big 4 accounting firm having worked for their Montreal, Toronto, Vancouver, Edmonton, Halifax, Miami, Seattle, New York, Los Angeles, Hawaii, Denver, Phoenix, and Irvine, California offices. John has headed an international high wealth practice and has been involved in personal tax minimization having extensive experience with the individual tax aspects of international executive transfers and wealth transfer planning. More recently, John has been involved in sophisticated U.S. corporate tax planning assisting U.S. based and foreign based multi-nationals with cross-border transactions including corporate restructuring, acquisitions and divestitures. John has had both inbound and outbound experience for public and private multi-nationals. He has assisted various multi-nationals with developing and implementing efficient global tax structures while not compromising their business operations. He has assisted various multi-nationals in meeting their U.S. international tax reporting obligations as well as assisted in the audit, preparation and review of ASC 740 – Accounting for Income Taxes. John has served clients in the following various industries such as Hospitality, Hi-Tech, Manufacturing, Education, Transportation, Real Estate, Insurance, Pharmaceutical, Healthcare, Construction & Engineering, and Energy. Mr. Apuzzo is a member of the American Institute of Certified Public Accountants, California CPA State Society, Illinois CPA State Society, newly created Canadian Chartered Professional Accountant (unification of the Canadian Institute of Chartered Accountants and the Society of Certified Managements Accountants of Canada), and the Canadian Institute of Chartered Business Valuators. He is also a member of the Canadian Tax Foundation and Society of Trusts and Estate Practitioners.
Maja M. Arcyz is a Managing Director in the Tax practice of KPMG. She has extensive experience providing international tax advice to multinationals in a variety of contexts, including acquisitions and divestitures, reorganizations and restructurings, joint ventures, technology and intellectual property transfers, and financing. She has also assisted various private equity and other alternative investment funds with tax matters related to their creation and operations. Maja joined KPMG in September of 2011. For the nine years prior to joining KPMG, Maja was an attorney with Arnold & Porter LLP in New York, where she served a variety of multinational and individual clients. Earlier in her career, Maja was with Deloitte & Touche LLP, where she focused on transfer pricing and other cross-border tax matters. Maja has advised clients on issues related to inbound and outbound activities, including matters relating to Subpart F, passive foreign investment companies, real estate and other investments in the United States, treaty interpretation and application, transfer pricing, foreign currency transactions, foreign tax credits, and withholding and information reporting regimes. LL.M. (Taxation), New York University School of Law. Maja earned her LL.M. (International and Comparative Law) from Cornell University School of Law; her J.D. from Cornell Law School; her M.B.A. from Cornell University – Samuel Curtis Johnson Graduate School of Management; her B.A. from Harvard University and is a Member of the New York and New Jersey Bars.
Sherif Assef joined Duff & Phelps in 2012 as a managing director in the New York office. He has been named one of the world’s leading transfer pricing professionals by Legal Media Group and has extensive experience advising clients on a variety of transfer pricing matters. Prior to joining Duff & Phelps, Sherif helped build Ceteris into a world-class transfer pricing firm. Previous to Ceteris, Sherif was with Ernst & Young LLP, working with clients in the financial services, publishing, commodities, software, retail goods, telecommunications, energy, engineering, and construction industries. As lead economist in E&Y’s financial services transfer pricing practice in New York, he assisted clients in analyzing a variety of related party transactions – including the global trading of financial instruments, asset management services, brokerage services, the sharing of banking fees, insurance and re-insurance transactions, loans, guarantees, management services, and administrative services. Sherif has also performed activity-based costing analyses of intercompany and interdepartmental charges. Sherif holds a PhD in economics from Fordham University and has spoken at numerous conferences and seminars regarding transfer pricing.
Yosef Barbut is a tax partner in BDO National Tax group specializing in accounting for income taxes. In his current role, Yosef works in the firm's National Accounting Office dealing principally with client income tax accounting issues. Yosef is also involved in standard setting, development and publication of technical guidance related to income tax accounting. Prior to joining the National Office, Yosef was the director on one of PwC's largest non-audit, income tax accounting outsourcing engagement where he was responsible for a team that generated the consolidated income tax provisions as reported in the client's financial statements. Yosef started with PwC in 1997 working in the Houston office. Yosef is a graduate of the University of Florida.
Jeff Borchers is a Tax Director with the Federal Tax practice at KPMG LLP in the Houston office. He has both public accounting and legal experience advising clients on various tax matters in the engineering and construction, energy and real estate industries. Jeffery has 18+ years of financial experience which includes leading the Tax and Treasury functions at Willbros Group, Inc., working for the IRS Office of Chief Counsel as a tax advisor and advising clients in various tax matters while at KPMG and DLA Piper in Chicago. Some of Jeff’s key contributions to his former employers and clients include: Changing the corporate domicile of Willbros which saved more than $5 million annually; Determining foreign earnings and profits and formulating cash repatriation strategies to advise executive management on whether to repatriate foreign cash or to use revolving credit facility; Reorganizing Canadian operations into deferral partnerships preserving $10 million of cash flow in 2008 and $8 million in 2009; Lead due diligence teams for all business functions on one international acquisition with deal value of approximately $140 million and two domestic transactions worth $480 and $24 million. Jeffery also works with auditors on ASC 740 for major international companies and represents companies in tax controversy matters. Jeffery received his B.S. (Accounting) from DePaul University; his J.D. from John Marshall Law School. He a member of the Illinois State Bar and also passed the CPA examination.
Chi-May Brewer is an economist in Baker & McKenzie's Houston office. She has managed transfer pricing studies for multinational corporations on a broad range of transfer pricing issues and in a variety of industries. Ms. Brewer also performs financial modeling and analyses. Prior to joining Baker & McKenzie, she worked at Big Four accounting firms and in the airline industry where she performed many financial and economic analyses. Ms. Brewer works extensively on global transfer pricing issues, including planning intercompany pricing, overhead allocation, restructuring intercompany arrangements, and documenting tangible, intangible, and services transactions for tax purposes. Her experience covers a wide variety of industries, including oil and gas services, contract research organizations, chemicals, equipment manufacturers, and engineering and related services. In addition, Ms. Brewer has performed many financial modeling and economic analyses, including valuing the returns of internal projects, as well as forecasting company and industry financial results. Ms. Brewer received her M.B.A. from Georgetown University McDonough School of Business and her B.A. (cum Laude) from the University of Pennsylvania.
Kevin Burke is a Principal in Ernst & Young’s International Tax Services group in Boston. Kevin has over 15 years of transfer pricing experience with Ernst & Young and currently assists Northeast Area clients with a range of international tax planning, compliance, due diligence and controversy support transfer pricing services. Kevin has substantial experience in advising companies on the valuation of intellectual property in connection with implementation and documentation of global supply chain engagements. Prior to joining Ernst & Young's Northeast Area, Kevin was with the Firm's National Tax practice in Washington D.C. Kevin graduated from Trinity College in Hartford, Connecticut in 1994 with a B.A. in Economics and is an accredited member of the American Society of Appraisers specializing in business valuation.
Amy Cannefax is a Sr. Manager in the Federal Tax Practice at KPMG LLP, specializing in Tax Transformation and Outsourcing. Amy has over 30 years of tax and management accounting experience in the Financial Services Industry with over 13 years as the Tax Director of a large financial services company. Amy’s combination of tax and management accounting experience provides her with a broad perspective of the issues faced by tax departments and CFO organizations. Her experience includes: Federal, State and local taxation of insurance companies, banks, mutual funds, real estate transactions and partnerships; Life/Non-life consolidated return filing; GAAP and Statutory tax provision preparation; Information reporting; Payroll; Change Management team lead for a CFO transformation effort; Project Leader for implementation of a new payroll system; Business Valuations. Amy received her B.B.A. from University of Texas; is a CPA; Certified Management Accountant (CMA) and Accredited in Business Valuation (ABV).
Chuck Chubb is the Managing Director at WTAS in Philadelphia. Chuck Chubb has over 30 years of experience in advising a broad range of clients on federal, international and state and local tax matters. Before joining WTAS, he was a Tax Partner in two international professional services firms. Chuck is WTAS’ firm wide practice leader on Accounting for Income Taxes (FASB ASC 740) services, including US, non US, State & Local income taxes, and uncertain tax positions. He has extensive experience in preparation or review of tax-accrual work papers supporting computations of income tax provisions in company financial statements; Tax accounting for special situations, including mergers and acquisitions and foreign operations; Determination of level of sustainability of uncertain tax positions (FIN 48); Drafting or reviewing footnote disclosures of tax matters in company financial statements; Evaluation and documentation of valuation allowances; Income tax accounting in fresh-start accounting cases. Chuck’s clients span numerous industries, including retail, manufacturing, communications and financial services. Chuck has spoken locally and nationally in numerous venues regarding ASC 740 matters. Chuck attended Bloomsburg University, where he received his BSBA in Business Administration – Accounting.
Robert A. Clary II is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Chicago office. Rob’s practice focuses on international and domestic tax planning for multinational companies, including advising clients with respect to the tax aspects of domestic and cross-border acquisitions, divestitures, spin-offs, corporate restructurings, joint ventures and other corporate activities. Rob also represents multinational enterprises and other clients in international transfer pricing and tax controversy matters relating to cross-border operations, investments and transactions. Rob was selected as a 2013 Illinois Super Lawyers Rising Star. Prior to joining McDermott, Rob worked for a “Big Four” accounting firm in the mergers and acquisitions group of the Washington, D.C., national tax office. Rob is an Adjunct Professor at the Chicago-Kent School of Law, where he teaches Taxation of International Transactions. Rob is admitted to practice in Illinois. Rob received his J.D., magna cum laude and Order of the Coif, from the University of Miami School of Law; his LL.M. from
Jason R. Connery is a principal at KPMG LLP in the International Tax group of the Washington National Tax practice. He provides tax advice to foreign-based multinational companies, including insurance companies, and private equity funds on a wide range of matters, including branch taxation, FIRTPA, sourcing of income, allocation and apportionment of expenses, foreign currency taxation, and income tax treaty issues. He also provides tax advice to U.S.-based multinational companies on matters involving offshore earnings deferral, foreign tax credits, subpart F, and foreign currency and interest rate risk management in offshore treasury centers. Jason has worked extensively in the area of cross-border finance and financial products. He is a frequent speaker and writer on U.S. international tax issues. Jason rejoined KPMG LLP in 2006. Prior to that, he was a director of the Structured Finance Group at an investment bank in New York City, where he developed and implemented cross-border financings for the investment bank. Previous to working at the investment bank, Jason was a senior manager in the International Corporate Services group of KPMG’s Washington National Tax practice. Before that, Jason was a member of KPMG’s Financial Services practice in New York City, working primarily with foreign-based financial services institutions engaged in business in the United States. Jason earned his LL.M. from New York University, his JD, cum laude from The John Marshall Law School, and his BS in accounting, with honors, from University of Florida.
Brendan Cox is a Partner at Ernst & Young LLP, in the East Central Sub Area Federal Tax Practice, with over 17 years experience as a tax professional and over 9 years of specialized federal tax accounting methods experience. The issues Brendan has focused on include tax accounting for income and deductions under the all events test, tax accounting for advance payments, capitalization issues, distinguishing a change in facts from methods and Section 199 (the domestic manufacturing deduction). Brendan has successfully managed the implementation of several large federal tax projects, including multi-phase, comprehensive “turn-key” implementations. Many of these projects also included mining and manipulating substantial amounts of data using various technology tools. In addition, his projects have incorporated statistical sampling processes where appropriate and representing those results to the IRS. Brendan has spent substantial time working with clients in the manufacturing, telecommunications, pharmaceuticals, computer software, utilities, and media industries. Brendan is a frequent speaker on federal tax matters. He has addressed the Tax Executive Institute and internal Ernst & Young education programs and client seminars. Brendan holds a Bachelor of Science degree from Villanova University and an MBA from the University of Notre Dame. Brendan is licensed by the State(s) of Maryland, New Jersey, and Pennsylvania as a Certified Public Accountant.
John Crucs is a senior manager in the international corporate services group at KPMG LLP where he provides tax consulting services to a broad range of multinational clients. He has over fourteen years of tax experience based out of Boston, New York, and New Jersey. His practice involves advising clients on structuring and managing their global operations to reduce their worldwide effective tax rates. In addition to global tax planning, John has experience with other tax matters including preparing and auditing U.S. corporate tax provisions, preparing and reviewing U.S. corporate international tax compliance, and responding to audit inquiries by U.S. and foreign taxing authorities. Prior to joining KPMG, John was a tax director at the global luxury goods company LVMH, where he was responsible for U.S. tax planning and operations. Prior to that, he served as a senior tax manager at Deloitte and a senior associate at Andersen. John received his B.A. from The College of the Holy Cross in 1995 and his J.D. from Boston College Law School in 1998. He is a member of the tax section of the New York Bar Association. John earned his JD from Boston College Law School; his BA from The College of the Holy Cross and is a member of the New York Bar Association, Tax Section.
Paul Dau is counsel in the law firm of McDermott Will & Emery LLP based in the Firm's Silicon Valley office. He focuses his practice on complex international transactions involving intangibles, and on the resolution of federal tax controversies, from pre-audit preparation through litigation. He has represented clients in disputes before the U.S. Tax Court, U.S. Courts of Appeals, the Internal Revenue Service’s Appeals Division and the Internal Revenue Service National Office in a broad variety of matters. Paul has extensive experience with all aspects of cross-border use of intangibles, including overlaps and conflicts between financial statement and tax valuations and disclosures, as well as the interactions between tax and IP law. Paul’s practice also includes representation of clients in IP litigation relating to patents. Paul is a frequent speaker at Tax Executives Institute meetings and has made numerous presentations at professional conferences on issues relating to cross-border use of intangibles, including the interactions between tax law and IP law in such areas. Paul has published extensively in both areas. Paul received his undergraduate degree with first-class honors and was awarded the Prince of Wales Gold Medal and the Dow-Hickson Scholarship in the Humanities. At the University of Pittsburgh, Paul was the recipient of Canada Council Doctoral Fellowships.
Joseph Esperance is a member of Ernst & Young LLP’s International Tax Services practice for the Northeast Sub-Area. He is based in New York. Joseph has worked with clients in a variety of industries, including oil and gas, power and utilities, diversified industrial products, retail and wholesale, media and entertainment, and life sciences. Joseph assists both US and foreign multinational clients with all aspects of US international tax planning and compliance. In particular, Joseph has assisted clients with matters such as cross-border acquisitions, dispositions and restructurings, cross-border financing and repatriation, Subpart F, foreign tax credits, foreign earnings and profits, dual consolidated losses and debt/equity characterization. Joseph also assists clients with US income tax accounting using standards established by the Financial Accounting Standards Board (FAS 109 and FIN 48), US withholding tax and income tax treaties, US trade or business and effectively connected income, and partnerships and joint ventures. Joseph has also served as a member of global Ernst & Young organization’s US Tax Desk network in the Europe, Middle East, India and Africa (EMEIA) Area, where he was based in Milan, Italy with Studio Legale Tributario, a member firm of Ernst & Young Global Limited. Prior to joining the global Ernst & Young organization, Joseph held international tax positions within the corporate tax departments of Fortune 500 companies in the power and utilities and oil and gas industries. Joseph has served as a presenter and instructor for numerous professional organizations in the US and Europe. He has served as an adjunct professor at the University of St. Thomas and University of Houston-Downtown which are located in Houston, Texas. Joseph has a Bachelor of Science in Accounting and a Master of Science in Accounting (Tax concentration) from Louisiana State University. He is a certified public accountant licensed to practice in Texas and a member of the American Institute of Certified Public Accountants.
Tim Fitzgibbon is a Director in the International Tax Services group of PricewaterhouseCoopers in San Jose. Prior to joining PwC, Tim was a Senior Associate at Fenwick & West, one of the top law firm tax practices on the West Coast. His practice focuses on international tax planning for both the outbound operations of U.S. multinationals and the inbound operations of foreign multinationals. This includes advice on domestic and international tax planning, structuring mergers and acquisitions, internal restructurings and operations, and joint ventures. Tim has co-authored and authored articles on U.S. international tax rules and developments. He has lectured to professional and industry groups on various topics including the provisions of Subpart F, foreign currency, dual consolidated losses, the foreign tax credit, and international partnerships and joint ventures. Tim attended law school at Loyola Law School, graduating with a J.D., cum laude, Order of the Coif, in 1998 and received an LL.M in Taxation from New York University School of Law in 2001.
Steven M. Davis is a Principal in the International Tax Services group at Deloitte Tax, LLP’s New York City office with over 22 years of international tax experience. Steven is the East Regional Leader of Deloitte’s Business Model Optimization (BMO) practice and is a member of the global BMO leadership team. The BMO practice focuses on helping multinational companies across all industries integrate their operational and tax planning in a scalable and sustainable way to help business leaders make more effective decisions on an after-tax basis. Steven has extensive experience assisting US and non-US multinational organizations in identifying and implementing strategies for minimizing global taxation. These strategies encompass matters related to the migration of intangibles, supply/value chain planning and other business transformation strategies. In this regard, he has significant practical experience in the assessment, design, implementation and post-implementation maintenance of global strategies to achieve sustainable tax-aligned operational synergies for some of the firm’s key clients. An integral part of his experience includes project management and effective resolution of critical business, tax and legal issues, through careful and pro-active coordination between the client’s financial and operational stakeholders driving such business transformation strategies. Prior to joining Deloitte, Steven was the International Tax Director at Loral Space & Communications Ltd. Prior to that, Steven practiced tax law in the New York City office of the law firm of Akin, Gump, Strauss, Hauer & Feld, LLP. Steven obtained his LL.M. (Taxation) from NYU School of Law, his JD from Hofstra Law School and his BS (Accounting) from Syracuse University. Steven also is a frequent lecturer on topics related to IP and supply chain planning.
Rui Fan is a Managing Director at KPMG LLPin New York. Rui has 11 years of experience in advising multinational companies on transfer pricing, valuations, business restructuring, intellectual property planning, and other tax and financial related issues in the United States and Asia-Pacific region. Rui also spent over one year in Singapore in developing the transfer pricing teams in Asia Pacific. Rui has performed transfer pricing planning and documentation engagements related to tangible property, intangible property, and services with a focus on intangible-related issues, such as licensing arrangements, cost sharing arrangements and intangible sales for clients in the pharmaceutical industry. Her clients cover a broad range of industries, including fast-moving consumer goods, consumer electronics, industrial markets, agricultural products, the retail industry, software, and financial services industries. In addition, Rui provided valuation services for both U.S. and international, public and private businesses for the purposes of mergers and acquisitions, corporate restructuring, property tax, employee stock ownership plans, divestitures, financial (ASC 350 and 805), and tax reporting. In connection with these assignments, she valued the following securities and assets: publicly-traded and closely held common stock (on both a controlling and minority level), preferred stock, stock options and warrants, debt instruments, software, warranties, customer relationship, trade names, patents, non-compete agreements, licenses, software, copyrights, trained workforce, and contracts. Rui received her M.S. in Management Information Systems from Carnegie Mellon University and her B.S. from International Finance at Renmin University of China.
Paul Flignor is a Principal Economist with DLA Piper'sTax group based in Chicago. He concentrates his practice in intercompany pricing and intellectual property valuation. He has more than 17 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing and financial economics. He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies. Mr. Flignor has worked extensively in the automotive, information services, software, consumer products and electronics industries. Over the years, he has successfully run transfer pricing and valuation projects for a variety of purposes, including: Intercompany pricing, including audit defense, Advanced Pricing Agreements, cost sharing and intangible migration, and global documentation; Business valuation for both tax and financial reporting purposes, including purchase price allocation; Transaction support, including due diligence analysis and pre- and post merger integration planning; Intellectual property valuation and management.
Victor Gatti is a Principal with KPMG’s New York Financial Services Practice (NYFS) and the New York Merger and Acquisitions Practice. Victor re-joined KPMG in October 2011, after a 5-year assignment as a Partner at Jones Day. While at KPMG, Victor has provided technical assistance to a wide variety of clients in a number of industries: Providing structuring and tax efficient post-acquisition implementation services in addition to general consulting structuring for a major Pharmaceutical company for over 12 years; Post-acquisition tax planning and consulting services for a number of private equity fund clients. While at Jones Day, Victor handled all areas of federal taxation, advised US- based multinationals in the US, assisted restructuring businesses to maximize their tax efficiency and assisted numerous clients in a variety of industries, including: Due diligence for mergers and acquisitions; Structuring cross-border joint ventures; Assist lenders and borrowers in reviewing credit agreements. Victor received his BA from University of Connecticut; his LL.M from NYU School of Law and his Juris Doctor from Western New England College School of Law.
Alexander Hanhan is a Tax Managing Director with the International Corporate Services group in KPMG’sHouston office. Alexander works with many multinational clients, primarily oil field services and manufacturing industries, on international tax-related projects. He consults on cross-border reorganizations, acquisitions, dispositions and other debt-financed transactions. Alexander provides tax advice on efficient business structures for U.S. based businesses expanding into global markets and foreign-based businesses expanding into the U.S. He assists with the international aspects of U.S. tax and financial reporting, earnings and profits calculations, foreign tax credit calculations, U.S. GAAP and IFRS, and other compliance projects. Alexander speaks on international tax matters for organizations such as the Tax Executives Institute, the Council for International Tax Education and Networking Seminars. Alexander earned his Masters of Laws in Taxation from New York University; his JD from Brooklyn Law School and his BA in Business Economics from University of Texas.
Mike Hardgrove is a partner in DLA Piper's Tax practice, based in Boston. He has provided international consulting, structuring and intangible transaction services to numerous public and private companies with operations throughout the world. Mr. Hardgrove focuses his practice on international taxation, concentrating in particular on global business structuring (GBS), a process of assessing international tax and operating cost exposures and then designing strategies for management of cost efficiency and key value drivers. Primary objectives of this process are to reduce the after-tax cost of capital and to lower the effective tax rate on profits from foreign activities. This includes: Assessing the tax risks inherent in international sales, distribution or manufacturing operations, and evaluating the international structure, transaction flow, value-chain and business transition plans; designing a strategy that can be integrated into international business functions such as trading companies, shared services centers, regional headquarters, procurement/sourcing offices, distribution centers, holding companies and/or treasury centers, and implementing principal operating models for European and APAC businesses, tax deferral structures, tax-efficient treasury management, entity restructurings, holding structures and acquisition structuring. Before joining DLA Piper, Mr. Hardgrove was with PricewaterhouseCoopers for more than 20 years, working in PwC offices in Brussels, San Jose/San Francisco and Seattle. He has served as PwC’s US leader for global structure alignment and as the national tax leader of the industrial manufacturing industry sector. Earlier in his career, he worked as a controller and auditor for six years. He is a member of the Massachusetts Bar, California Bar and the Ohio Society of Certified Public Accountants and is a Certified Management Accountant (CMA). Mr. Hardgrove has taught international taxation courses as an adjunct faculty member in the law school LLM programs at both the University of Washington and Golden Gate University. He is a frequent speaker and instructor on international taxation, migration, deferral and strategic planning matters. He has also written articles on international taxation, intangible property planning, global business issues, cross-border income taxation and planning for global expansion for the Journal of Accountancy, International Tax Review, CCH, the California Bar Journal and publications of the Canadian Tax Foundation. He is a contributor to PwC's Mastering the Intellectual Property Life Cycle, which discusses tax-efficient management of IP rights.
Justin Hill is an associate with Baker & McKenzie in New York. His practice focuses on a wide range of federal income tax matters, including domestic and international tax issues related to mergers, acquisitions, and dispositions as well as equity and debt offerings. Justin began his career as a certified public accountant with KPMG LLP's state and local tax practice in 2004 and subsequently worked in the state and local tax practice at another international law firm before joining Baker & McKenzie in 2012. He received his J.D. magna cum laude from Fordham University School of Law and his B.B.A. from Baylor University.
Mark Horowitz is an associate in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Houston office. Mark represents multinational enterprises in international transfer pricing and tax controversy matters. He advises clients with respect to Advance Pricing Agreements, Competent Authority cases, the planning, structuring and documenting of controlled group transfer pricing arrangements, and the accounting and reporting of uncertain tax positions. He has significant experience in U.S.-Japan, U.S.-United Kingdom, and U.S.-Canada Competent Authority cases and Advance Pricing Agreements. Mark’s clients include companies from the consumer products, software, engineering and construction, chemical, and oil field services industries, among others. Mark regularly represents clients in tax controversies before the Internal Revenue Service and state and local tax authorities, and handles litigation in transfer pricing and other contexts. In addition to his tax controversy work, he advises clients on a broad range of state and federal tax issues. Mark has been named a “Texas Rising Star” by Law & Politics Media Inc., as published in Texas Monthly Magazine. He has spoken on tax-related topics, including transfer pricing, Competent Authority proceedings and Advance Pricing Agreements, at numerous tax conferences. Mark is admitted to practice in Texas and before the U.S. Court of Federal Claims and the U.S. Tax Court. He earned his J.D. from University of Virginia School of Law and his B.A. from Harvard University.
Matvey Kats is a Senior Manager in the New York office of Deloitte Tax LLP’s International Tax Practice with over 6 years of experience in US International Tax. His practice focuses on developing optimal tax structures for proposed reorganizations, mergers, and acquisitions for US and foreign based multinational companies in corporate and private equity contexts. Matvey’s specific areas of focus include outbound and inbound transfers, taxation of passive income, foreign tax credit utilization, anti-conduit regulations, inversion transactions, treaty qualification, permanent establishment, and foreign investment in US real property. Matvey received his BBA in Accounting from CUNY Baruch College and his JD from Brooklyn Law School.
Ryan P. Keane is the founding member of Tax Resource Connection, LLC in the Town of Brookfield, Wisconsin. He advises U.S. foreign direct investment clients and large U.S. multinational corporations regarding international tax issues arising in their daily operations. He also represents clients before the IRS. During his 20-year career, Ryan has advised clients on a wide range of international tax matters including tax optimized inbound finance structures, withholding tax considerations, tax treaty benefit interpretations, and deemed international tax asset purchase elections. In addition, he has provided transfer pricing documentation services, U.S. tax credit planning for international taxes paid, and acquisition integration assistance. From 1996-1998, Ryan resided and served clients in Toronto, Ontario. Ryan earned a B.A. in Business Economics from Wheaton College in Illinois and a M.A.S. in Taxation from Northern Illinois University. He is a Certified Public Accountant, licensed to practice in Illinois and Wisconsin.
William (Bill) King is a Director, Compensation & Benefits at Grant Thornton LLP and has over 25 years of experience in providing tax, executive compensation and benefit consulting services to wide range of industries including energy, financial services and manufacturing companies. Prior to joining Grant Thornton LLP, Bill served in leadership roles for both “boutique” and Big four Accounting firms providing executive compensation and benefit consulting services. Bill has specific experience in the design and implementation of executive compensation plans including long –term incentive plans (both equity and cash base designs), annual bonus plans, SERPS, retention plan strategies, ASC 718, IRC 409A, IRC 162(m) and IRC 280G. In addition, Bill has assisted clients on numerous IRS compliance issues related to compensation and employee benefit plans including corrections through Employee Plans Compliance Resolution System (EPCRS), Voluntary Compliance Program (VCP) and Correction on Audit (CAPs), DOL Penalty Abatements, on-site audits, reasonable compensation and 501(c)(9) deduction issues. Bill earned his BS in Psychology from Florida State University and his BA Business Administration from University of South Florida.
Kathrine Kimball is a principal of Deloitte Tax LLP in the San Diego office. Ms. Kimball’s extensive experience includes both international and domestic transfer pricing, encompassing documentation, planning, and controversy defense as well as supply-chain based tax planning. Ms. Kimball has served major multinational clients in a wide range of industries, including: apparel, automotive, bio-tech, chemicals, construction, consumer products, electronics, financial services, food and beverages, including beer, wine, and spirits, gaming, pharmaceuticals, professional services, real estate, retail, and technology. Having specialized in transfer pricing for over 20 years, she has managed a multitude of global, pan-European, pan-Asian, and North American international supply chain transformation or post-merger integration projects, as well as the US domestic aspects of such projects, involving the restructuring and optimization of the tax structure within the context of a business reorganization. Kathrine has been named again among the "World's Leading Transfer Pricing Advisers" in the 2013 Expert Guide published by Euromoney's Legal Media Group. She has also been named by in-house counsel in both the first and second edition of Euromoney's "Guide to the World’s Leading Women in Business Law" in 2012 and 2013.
Neal Kochman is a member ofChaplin & Drysdalein Washington, DC. Mr. Kochman's practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters. His experience covers a broad range of international, domestic, and state tax issues associated with transfer pricing, foreign tax credit planning, corporate restructurings, qualified settlement funds, and withholding and reporting. Mr. Kochman regularly advises clients on tax controversy matters, providing assistance during tax audits and representation in IRS Appeals proceedings, as well as in technical advice and ruling requests to the IRS National Office. He has represented U.S. multinational companies and U.S. subsidiaries of Belgian, German, Swedish and other foreign parents in advance pricing agreement and competent authority negotiations. Prior to joining Caplin & Drysdale, Mr. Kochman spent over 20 years performing quantitative and policy analyses for federal government agencies, which included: conducting econometric and statistical studies and developed cost allocation and pricing models, developing renewable energy research and development plans, and conducting defense acquisition policy studies. Mr. Kochman has written, been a guest lecturer at Georgetown University Law Center, and spoken at professional meetings on a variety of international and general tax topics, including foreign tax credits, transfer pricing, and the research credit. Mr. Kochman received his J.D. from Georgetown University Law Center, cum laude; Georgetown Law Journal; his M.I.E. from Cornell University and his B.S. from Cornell University.
Nelly Korsun joined Duff & Phelps as a director in the New York office. Nelly has over ten years of experience providing economic and business consulting services in the areas of transfer pricing and valuation. Throughout her career Nelly has advised clients on complex transfer pricing issues for global tax planning, documentation and supply chain restructuring initiatives. She has provided litigation and audit defense support in controversy matters, advised on intangible property valuation issues and cost-sharing arrangements, and performed transfer pricing reviews within M&A due diligence processes. Nelly also has considerable experience advising clients’ senior management teams on issues surrounding intercompany financing, including debt capacity, interest rates, risk transfers, guarantees and cash pooling arrangements. Nelly assists clients across a number of industries, most notably life sciences and medical devices, and financial services. Her client base also includes companies within specialty chemicals, automotive, consumer and industrial products, and telecommunications. Prior to joining Duff & Phelps, Nelly was a director at Ceteris, an independent transfer pricing and valuation firm. She also spent several years with BDO Seidman LLP and Charles River Associates. Nelly received her M.B.A., with honors, from the Johnson School at Cornell University, and a B.A. from Barnard College at Columbia University. She also holds a professional certificate in Credit Analysis and Credit Risk from the New York Institute of Finance and is progressing towards a certification in Business Valuation from American Society of Appraisers (ASA).
Frank Landreneau is a CPA and Director of International Tax Services at Pannell Kerr Forster of Texas and has extensive experience providing domestic and international tax consulting and compliance services to private as well as public entities located within Texas and Louisiana. He has consulted with companies doing business in the banking, construction, technology, oil field services, and manufacturing/distribution industries. His experience also includes assisting clients operating in various foreign tax jurisdictions with a variety of international tax issues, such as transfer pricing, global tax minimization, and international organizational structuring. Additionally, he has consulted with companies on a number of complex tax issues related to acquiring and divesting of subsidiaries in order to realign their businesses. During his years in public accounting, he has assisted clients with accounting method changes, flow-through tax planning, IC DISCs, and FAS 109 deferred tax analyses, as well as uniform capitalization issues, IRS examinations, and other tax planning techniques. While at PKF Texas, Frank has become the outsource solution for international tax services for many offices within PKF North America. Frank’s expertise also includes repatriation planning involving foreign holding company structures. Frank has also worked with a number of foreign companies in structuring their U.S. business operations. In particular, Frank serves a number of clients based in Europe, including those in the United Kingdom, Germany, Italy, and the Netherlands. Frank also chairs quarterly international conference calls for the Leading Edge Alliance. Frank is a Certified Public Accountant in Texas. He received his BBA in Accounting from the Louisiana State University and his MS in Accounting and Taxation from the University of Houston.
Erin Lien is a member of Ernst & Young LLP’s International Tax Services group in New York. Erin’s primary areas of concentration include international tax advisory services, including tax efficient supply chain management, cross-border restructuring transactions, Subpart F considerations and other issues related thereto. Her practice includes both inbound and outbound US tax matters. Before joining Ernst & Young LLP, Erin was an associate with Baker & McKenzie LLP’s New York office. At Baker & McKenzie, Erin’s practice covered a wide range of tax issues, including U.S. federal, state and local, transfer pricing, and international tax practice, before focusing her practice on international tax planning. While at Baker & McKenzie LLP, Erin served as Secretary of the New York City Bar’s Committee on Pro Bono and Legal Services. Erin holds B.A.s in Economics and Spanish from the University of California, Los Angeles (Provost’s honors), a J.D. from Georgetown University Law School, and an LL.M. in Taxation from New York University School of Law. Erin also holds a Certificate in Spanish Studies from the Universidad de Salamanca. While at Georgetown, Erin was a member of the Institute for Public Representation, Communications Division, an editor of the Georgetown Law Weekly and a Georgetown Student Ambassador. Prior to entering the field of tax law, Erin served as a law clerk for the Office of the District Attorney of Santa Clara County, Juvenile Dependency Unit, and as an intern to the White House. Erin is licensed to practice law in New York and in California. She has published several articles addressing a range of tax issues. She is a member of the American Bar Association, as well as a member of Mensa.
Jason LaRosa is a Director at KPMG LLP in Houston. Jason works with many multinational clients, primarily in the oil field services, offshore drilling and manufacturing industries, on international tax-related projects. He consults on cross-border reorganizations, acquisitions, dispositions and debt-financing, specializing in structuring transactions to minimize worldwide taxes. Jason provides tax advice on tax efficient business structures for U.S. based businesses expanding into global markets and foreign-based businesses expanding into the U.S. He assists with the international aspects of U.S. tax and financial reporting, earnings and profits calculations, foreign tax credit calculations, U.S. GAAP and IFRS, and other compliance projects. Jason is a CPA and earned his Master of Laws in Taxation from the University of Missouri and his JD from Duquesne Law School and his BS in Accounting from St. Vincent College.
Jeffrey A. Levenstam is an international tax services partner at Ernst & Young LLPbased in San Francisco. He joined the Ernst & Young’s International Tax Services Group in 2005. Jeff has practiced international tax for over 33 years as a tax professional and corporate tax executive. Before joining EY, Jeff served as the Senior Director of International Tax, M&A and Customs at Cisco Systems, Inc. from 2000 to 2005. Prior to that, Jeff was a partner at another Big Four Firm. Jeff has extensive experience advising U.S. and foreign based multinational businesses in all aspects of international taxation, including transfer pricing, subpart F and dividend planning, capital structuring and foreign operational issues. Jeff also has extensive experience in structuring and operating IP ownership and tax efficient supply chain structures. Jeff also has a concentration of clients in the internet and software industries with their own set of supply chain/service issues related to server locations, PE challenges, revenue characterization issues, etc. Jeff has the experience of being the in-house executive responsible for Cisco Systems international tax and customs planning, compliance and tax audit defense work. He was also responsible for all tax aspects of acquisition planning and integration, strategic investments and alliances, and joint ventures while at Cisco. Jeff is a member of IFA and past member of TEI while a Cisco Systems tax executive, speaking on international tax topics for TEI and TCPI while a corporate tax executive. He was a speaker at the International Tax Conference held by the India and USA branches of IFA in New Delhi in 2006 and in Washington DC in May, 2009. Jeff has extensive experience with foreign tax audits, competent authority procedures and APAs. Jeff co-authored an article in Tax Management International Journal on US Multinationals Investing into India and a three-part article for investing into China. He has also co-authored an article on the new Contract Manufacturing regulations which was published in May, 2009 in TMIJ. Jeff is a licensed California CPA. He graduated with a BS in Accounting from the University of Illinois Urbana-Champaign campus.
Elizabeth Lieb practices in the area of corporate and international tax planning at Baker & McKenzie in Palo Alto, CA. Ms. Lieb’s practice emphasizes a variety of international tax planning matters for multinational corporations, including structuring and implementing international operations, such as intangible property arrangements, and manufacturing and services supply chains. She also advises on subpart F planning, tax treaties, and the tax aspects of multi-jurisdictional post-acquisition integrations and other corporate reorganizations. Prior to joining Baker & McKenzie in 2007, Ms. Lieb worked as a tax associate in the Menlo Park office of Shearman & Sterling LLP and as Attorney Advisor to the Honorable Carleton D. Powell of the United States Tax Court. Ms. Lieb has lectured on Section 956 Investments in United States Property for Bloomberg/BNA CITE, and Income Tax Treaties for Networking Seminars. Ms. Lieb is the co-author of Changes to the “Tax Shelter” Rules After the American Jobs Creation Act of 2004, Practical TaxLawyer (February 2006). Ms. Lieb is a member of the Taxation Section of the American Bar Association and the State Bar of California Taxation Section. She received her LL.M. (Taxation) from New York University School of Law; her J.D. cum Laude from California Western School of Law; and her B.S. (with honors) from the University of Iowa.
Narelle MacKenzie is a well known international tax consultantwith over 25 years of experience in international taxes, Her experience working with, or for, multinational companies enables her to develop strategic and practical solutions to minimize worldwide tax burdens. Ms. MacKenzie is also an International Tax lecturer at San Diego State University (SDSU), first appointed in 2007. She is located in San Diego, CA and works with CPAs, attorneys, and in-house tax departments worldwide. She has worked in both public accounting and industry for employers such as Goodrich Corporation (a Fortune 500 company that was acquired by United Technologies), PricewaterhouseCoopers LLP, and Toyota Australia. Her business experience has covered diverse industries and activities, including supply chain activities and initiatives, identification and implementation of new manufacturing facilities, establishing representative offices, secondment arrangements, customer sales and support initiatives and general cross-border issues. As well as lecturing at SDSU, she is a highly sought after speaker, course instructor and guest lecturer and has presented at many and diverse conferences including CalCPA, the ABA, AWSA and PwC. She is a Past President of CalCPA (San Diego chapter), and currently serves on the Audit Committee for St James by the Sea, La Jolla. Ms. MacKenzie is an Australia CPA and a California CPA.
Michael J. Masciangelo is a partner in and member of Ernst & Young LLP’sInternational Tax Services practice in Houston. Michael is responsible for leading Ernst & Young’s global resources in designing and implementing a variety of strategies for our clients. Michael has worked with several Ernst & Young offices since joining the firm in 1995 and has over 17 years of experience in corporate and international (inbound and outbound) tax. Michael has concentrated on both outbound and inbound clients across a broad range of industries. In addition to his specific client serving role, he serves as the firm’s International Tax Think Tank Leader for the Southwest Sub Area and performs a similar role for other international tax technical initiatives within the firm. Michael has been actively involved in advising our clients on opportunities to reduce their global tax burdens and minimization of risk. His work includes advising on internal and external restructurings, financing/repatriation, acquisitions, joint ventures, foreign tax credit matters, and tax implications of global supply chain initiatives. He has also been involved with complex tax provision reviews, research of and advising on tax accounting issues and has extensive experience in advising on matters of foreign source income and expense allocation and apportionment. Michael has B.B.A in accounting from Kent State University and Master of Taxation from the University of Denver. He is a certified public accountant licensed in the states of Ohio, Illinois, and Texas. He has instructed at internal seminars and many US and European client and educational seminars.
Nicole Michalovsky has been a member of Ernst & Young LLP's International Tax Services practice for the Northeast Sub-Area for almost seven years. She is an international tax manager based in New York. Nicole has worked with clients in a variety of industries, including pharmaceuticals, retail and wholesale, media and entertainment, and life sciences. Nicole assists in both US and foreign and multinational clients with all aspects of US international tax planing and compliance. In particular, Nicole has assisted clients with matters such as cross-border acquisitions, dispositions and restructurings, cross-border financing and repatriation, Subpart F, foreign tax credits and foreign earnings and profits. Nicole also assists clients with US income tax accounting using standards established by the Financial Accounting Standards Board (FAS 109 and FIN 48), US withholding tax and income tax treaties, US trade or business and effectively connected income. Nicole earned a Bachelor's degree in Finance and Economics from the State University of New York at Binghamton and a law degree from St. John's University.
Sean K. McFerson has more than 16 years of experience in public accounting and is currently a partner at Windes LLP in the firm’s Tax and Accounting Services practice. He specializes in domestic and international taxation issues of multi-national companies (both public and private), and start-up companies, including domestic and international restructuring, consultation on year-end and quarterly income tax provisions, tax-efficient integration of acquired targets, developing and implementing intellectual property-migration strategies, and formation of international entrepreneur structures. Sean’s expertise extends to consultation and preparation of various federal and international tax reports, such as net operating loss studies, accounting method changes, and miscellaneous foreign reporting. Sean serves a wide variety of clients in the technology, manufacturing, distribution, services, and high-net-worth individuals. Sean’s experience includes working abroad, in London, UK, where he worked at the United States Tax Desk for PricewaterhouseCoopers LLP. Sean has a Bachelor of Science in Accounting from Loyola Marymount University and a Master of Business Taxation from University of Southern California. He is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Robert J. Misey, Jr. is a shareholder at Reinhart Boerner Van Deuren in the firm's Tax and Business Law Practices and Chair of the International Practice. He concentrates his practice in the areas of international taxation and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment. Mr. Misey's previous legal experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney and as a trial attorney. Mr. Misey regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs. His speaking engagements have taken him to numerous states and foreign countries. Mr. Misey also teaches international taxation at the Master of Tax. Mr. Misey received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University.
Reza Nader is a member of Baker & McKenzie’sNorth America Tax Practice Group in the New York office, where he works on international tax planning and transactions. He is an active participant at both in-house and external seminars and conferences. Mr. Nader has also worked on various pro bono matters, including work with international development organizations. Mr. Nader has experience advising clients on international mergers, acquisitions, and dispositions, supply chain restructurings, and joint ventures and alliances. He also advises clients on dispositions of US real property interests, bankruptcy reorganizations, and income tax treaties, including competent authority matters. Mr. Nader served as an adjunct professor in Outbound International Taxation at the Georgetown University Law Center in 2011. He received his LL.M., in Taxation, with distinction, Deans List, Georgetown University Law Center; his J.D. from Emory University School of Law; and his B.A. with honors from Schulich School of Business in Toronto, Canada.
Ken O’Hara has been with KPMG for 15 years in Boston. Ken has worked on a wide range of engagements, including documentation, planning, assisting clients with responses to IDRs and IRS audits, APAs, and provision/FIN 48 reviews. During his tenure with the firm, Ken has gained experience with most types of intercompany transactions, including tangible, intangible, service and financial (loan/guarantee) transactions. He has also assisted clients with respect to the adoption of the temporary services regulations, and more recently, addressed questions regarding the temporary cost sharing regulations. Ken has assisted multiple clients (typically US manufacturing subsidiaries with foreign parents) in responding to IDRs. He has prepared transfer pricing documentation and planning work for clients in wide range of industries, including pharmaceutical, industrial (manufacturing), consulting, electronics, entertainment, food and beverage, publishing, and eyewear.
Klaus Oehring is the National Director of Transfer at UHY Advisors. Klaus is a CPA with 30 years of industry and public accounting experience. He practices in all areas of U.S. income taxation with special emphasis on international tax, transfer pricing and related tax accounting matters including ASC 740. Klaus has extensive experience preparing U.S. and foreign contemporaneous transfer pricing documentation and handling Advanced Pricing Agreements, Competent Authority and tax audit defense matters. Previously, Klaus worked as the International Tax Director for ClubCorp Inc., an International Tax Specialist for Dresser Industries, Inc., the Director of Transfer Pricing at Gardere Wynne Sewell, and as a Senior Manager for KPMG in Calgary, Canada, and Dallas, Texas. At Dresser, he was responsible for the annual tax footnote, directing the implementation of FAS 109 and establishing and modifying Dresser's worldwide transfer pricing strategies including the designing of contemporaneous transfer pricing documentation. He also directed the implementation of various intercompany arrangements, assisted division controllers in establishing intercompany prices for goods and services, and resolved several multi-country tax audits. At ClubCorp, Klaus was responsible for similar matters in the leisure and hospitality industry, including negotiating two Advanced Pricing Agreements. In addition, he has been involved in due diligence and tax planning related to several corporate mergers. Klaus is a frequent speaker at international tax and transfer pricing seminars. He developed a 2-day seminar titled “U.S. Transfer Pricing Primer” for Bloomberg BNA which deals with practical approaches to most common intercompany transfer pricing arrangements.
Ben Olivas is a partner in the International Tax group at DLA Piperin San Jose, CA. He concentrates his practice in international tax and operational structuring, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, post-acquisition integration, and tax controversy. He has worked extensively with US companies doing business in various parts of the world, as well as foreign companies expanding their US operations. Prior to joining the firm, he spent fifteen years at PricewaterhouseCoopers LLP, including seven years as a partner in the international tax group. As a partner in a Big 4 accounting firm, he dealt with international tax issues from both planning and tax provision perspectives.
Melinda R. Phelan is a member of the management committee for Baker & McKenzie's North America Tax Group. She is a regular presenter on tax issues for a broad range of conferences, including those organized by the Tax Executive Institute and Baker & McKenzie. She is a member of the Tax Section of the American Bar Association, as well as the State Bar of Texas and the Dallas Bar Association. Ms. Phelan assists clients — including multinational firms — with transfer pricing, as well as domestic and international tax planning. She has been involved in numerous global transfer pricing projects and advance pricing agreements. She also handles the legal aspects of designing and implementing structures to minimize global taxation, and is experienced in domestic and international M&A transactions. Ms. Phelan has worked on cases involving tax controversy, particularly at the audit, appeals and litigation levels. Ms. Phelan earned her J.D. (magna cum laude) from Tulane Law School and her B.A. (Honors) from University of the South.
Ken Picciano is a partner at KPMG LLP and has more than 20 years experience advising large and middle market multinational companies on a variety of international tax matters with a focus on cross-border mergers and acquisitions. Mr. Picciano works closely with KPMG’s mergers and acquisitions practice and foreign offices on a variety of cross-border acquisitions, mergers and restructuring involving both U.S. and foreign-owned multinational companies. Mr. Picciano has extensive experience dealing with foreign tax credit planning, repatriation planning, subpart F issues, international expansion and post-acquisition structuring. Mr. Picciano previously did rotation in KPMG’s Washington National Tax Practice, where he worked in the international corporate tax group. Mr. Picciano has co-authored “The Euro is Coming: A Look at Some of the Complex U.S. Tax Issues,” published in the Journal of International Taxation, March, 1998; Co-authored “Final Regs. Clarify Cost Sharing of R&D Expenditures,” published in The Tax Advisor, January, 1997. He is a frequent presenter at various international tax seminars in the Philadelphia region. Mr. Picciano is a graduate of the Philadelphia branch of Leadership, Inc., an organization that provides leadership training to residents of the Greater Philadelphia area Chapter. He received his M.S. in Taxation form Villanova University and his BA in Economics from Rutgers University. Mr. Picciano is a Certified Public Accountant.
James Prettyman is a partner in the Mergers and Acquisitions Group in PricewaterhouseCooper's Houston office. Previously, James was an M&A partner in PwC's Washington National Tax Services office. He specializes in corporate transactions and consolidated returns and cross border restructuring. James has over 20 years of experience in public accounting. James provides consulting services to the clients on numerous acquisitions, dispositions, restructurings and tax planning projects. These projects include optimizing the tax position of the clients on acquisitions and dispositions, tax basis and earnings and profits studies, section 382 analyses, and private letter ruling requests. He also has experience in cross-border restructurings, restructuring of consolidated groups in anticipation of REIT IPOs, internal spin offs, and several acquisition and disposition related consulting projects. In addition to his client responsibilities, Mr. Prettyman has participated in a number of panels for TEI, ALI/ABA and other organizations. James received his Bachelors of Business Administration in accounting and a Masters in Professional Accounting with an emphasis in tax from the University of Texas at Austin. He is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Brad Rolph is the National Leader of Grant Thornton's transfer pricing practice in Canada. Mr. Rolph has been providing transfer pricing consulting services to multinational companies for the last 18 years. He was the first economist hired by any of the Big Four accounting firms in Canada to practice transfer pricing exclusively. Euromoney's Legal Media Group recognized Mr. Rolph as one of Canada’s leading transfer pricing advisers in its 2013 "World's Leading Transfer Pricing Advisers" publication. His areas of expertise include planning, implementing and documenting intercompany transactions for tangible goods, services and intangibles in a tax-efficient, defendable manner (“TESCM”); building models to price complex financial transactions; resolving audit disputes at the field, appeals and Competent Authority level; negotiating advance pricing arrangements (“APA”); and providing litigation support. Mr. Rolph has served companies based in Canada, the United States, England, Ireland, Finland, France, Germany, Sweden, Saudi Arabia and Japan. He has dealt with issues in the following industries: Aerospace, Mining, Metals and Minerals, Pulp and Paper, Transportation, Heavy Manufacturing, Steel, Utilities, Automotive, Chemical, Pharmaceutical, Food and Beverage, Electronic, Financial, Wholesale Trade, Apparel, Consumer Goods and Entertainment. He also has extensive experience with Japanese trading companies and web-based businesses. Mr. Rolph is a frequent speaker and commentator on transfer pricing matters. Mr. Rolph has been published in International Tax Review, Euromoney and Tax Management International. Mr. Rolph received his MA in Economics from Queen’s University and his BA in Economics from Wilfrid Laurier University.
John G. Ryan is a Partner at Bingham McCutchen LLP in Silicon Valley. John focuses his practice on tax planning and audit defense, most notably in connection with international transactions and the development and use of intellectual property. Ranked in Chambers USAas a leading tax lawyer in California, he is described as “a one-stop shop…he can analyze problems from all angles,” with clients praising his “broad knowledge of international tax and transfer pricing matters,” as well as his “responsiveness and accessibility.” John is a frequent speaker at professional organizations, discussing topics such as research and foreign tax credits, international restructurings, and transfer pricing. He has also taught courses on international and partnership issues for the LL.M. program at Golden Gate University. John has written numerous articles on tax for various publications. John is honored by the Chambers USA, America’s Leading Lawyers for Business, Tax: California (2011–present); by Legal 500, Tax; Tax Controversy (2012–2013); and is voted Best Lawyers, Tax Law (2013–2014). John received his Juris Doctor from Stanford Law School; His Doctor of Philosophy from the University of California, Berkeley and his Master of Science from the University College Dublin.
Caren S. Shein is a Managing Director at KPMG LLP’s National Tax Office in Washington, DC. Ms. Shein advises clients on outbound and inbound international tax planning and compliance issues, including foreign tax credit, subpart F, expense allocation, and permanent establishment. Her particular area of expertise is the foreign tax credit, and she regularly writes, speaks and teaches in this area. Caren is the author or co-author of numerous articles, including “Uncovering the Covered Asset Acquisition Rules,” The Tax Executive (Sept.-Oct. 2010), “Emergency Economic Stabilization Act of 2008 – Throwing a Rope to the Ailing Financial Industry Tightens the Noose on Big Oil,” Tax Management International Journal (February 2009), “Temporary Regulations Deny Foreign Tax Credits for Amounts Paid Pursuant to “Structured Passive Investment Arrangements”, Tax Management International Journal (October 2008), “New Temporary Regulations Under Section 905(c): A Big Improvement but Puzzling Issues Still Remain,” Tax Management Journal (May 2008), “The IRS Proposes a New Approach to Determine the Technical Taxpayer – Will it Work?,” Journal of Taxation of Global Transactions (Fall 2006), “Section 905(c) – The Missing Piece of the Foreign Tax Credit Puzzle”, Tax Management International Journal (January 2002), and “A Fresh View of Overall Foreign Losses and Consolidated Returns”, Tax Management International Journal (May 1999). Prior to joining KPMG, Ms. Shein was an attorney advisor at the Internal Revenue Service, Office of Associate Chief Counsel (International). There she worked on rulings, regulations and litigation, primarily relating to foreign tax credits. Ms. Shein began her career as a law clerk to the Honorable B. John Williams, Jr., of the United States Tax Court.
Margaret A.R. Shulman is a Executive Director in Ernst & Young LLP’sInternational Tax Services group in New York. She has recently joined E&Y from an international law firm. Margaret’s experience also includes having clerked at the U.S. Tax Court for the Hon. David Laro. Prior to switching to a career in tax, Ms. Shulman was a corporate lawyer, and, prior to that, a professional musician. Ms. Shulman counsels corporate and individual clients on the U.S. federal income tax aspects of a variety of cross-border business transactions and restructurings. She also has experience in providing a collaborative advice on the tax planning involving several foreign jurisdictions. Corporate clients benefitting from Ms. Shulman’s advice include both public and private companies conducting business in a variety of industries, including pharmaceuticals, consumer products, and media and entertainment. Ms. Shulman holds a B.A. in music and psychology, a J.D., and an LL.M. in Taxation. She is an author of several articles on international tax topics. Margaret is admitted to practice law in Michigan and in the District of Columbia, and is a member of the American Bar Association and of the International Fiscal Association.
Moshe Spinowitz represents clients on a range of tax matters related to corporate transactions, including public and private company mergers and acquisitions, with a particular emphasis on international tax matters, cross-border acquisitions, and post-acquisition integration and restructuring transactions. In addition, Mr. Spinowitz advises clients on a range of tax controversy matters during all phases of IRS audits and appeals. Mr. Spinowitz’s experience includes advising a multinational pharmaceutical company in connection with the integration and restructuring of its operations following a large cross-border acquisition, advising pharmaceutical and technology companies in connection with the structuring of their intellectual property holdings, and successfully representing several multinational corporations before IRS appeals in connection with intercompany financing transactions. Prior to joining Skadden, Mr. Spinowitz served as a law clerk to Judge Michael Boudin on the United States Court of Appeals for the First Circuit, and Justice Antonin Scalia on the United States Supreme Court.
Jason “Jay” Tata leads KPMG’s International Corporate Services tax practice in New England. He joined KPMG in 1999 and was promoted to partner in 2007. Jay has over 15 years of public accounting tax experience and over the past 10 years he has focused on providing domestic and international tax structuring advice and tax due diligence assistance in acquisition transactions. Jay experience spans more than 75 buy side transactions, both domestically and internationally, ranging in size from $10 million up to several billion dollars. Participation in these transactions included coordinating and leading tax due diligence investigations, providing technical tax and transaction structuring guidance and reviewing purchase and sale agreements. Jay specializes in international corporate taxation and has a strong background in corporate and partnership taxation, mergers and acquisitions, and accounting for income taxes. Jay’s experience includes assisting multinational corporations with global tax planning, restructuring projects, foreign tax credit planning, and foreign cash repatriation planning. Jay received his BBA in Accounting, University of Massachusetts in Amherst and his MST from Golden Gate University in San Francisco. Jay is a Certified Public Accountant in Massachusetts and California and a Member of AICPA and Massachusetts Society of CPAs.
Gabriel Taubenfeld is a Senior Manager in Ernst & Young LLP’sInternational Tax Services practice. He advises multinational corporations and private equity investors on a variety of international tax matters related to cross-border transactions and general international tax planning. Gabe has advised on numerous cross-border M&A transactions, financing and reorganizations, ranging in value between $10m and $23b across a broad range of industries. In this regard he is experienced in transaction structuring, tax modeling, due diligence and pre and post-transaction restructuring. Gabe also regularly assists both US and foreign multinational clients with all aspects of US international tax planning and compliance. In particular, he has assisted clients with foreign tax credit planning, tax-effective cash repatriation planning, Subpart F planning, tax treaty issues, US trade or business issues and effectively connected income. Gabe received a B.A. in Accounting from the City University of New York at Queens College, a J.D. from Fordham University School of Law and an LL.M. in Taxation from New York University School of Law. He is a member of the Tax Section of the American Bar Association and is a certified public accountant in New York.
Steve Weerts is a partner in the Tax practice of DLA Piper LLP in Los Angeles. He is experienced in international tax and transfer pricing matters. He concentrates in international business and tax planning. He has advised on the tax aspects of international joint ventures, cross-border mergers and acquisitions, post-transaction integration, international corporate finance, capital market transactions, and general international tax planning matters. Mr. Weerts comes to DLA Piper from KPMG, where he was a manager in the International Corporate Tax Services group. He has also worked with the IRS Chief Counsel’s Office and in the tax department of Ascent Media Group. Mr Weerts received his LL.M., Taxation, from Loyola Law School; his J.D., Loyola Law School; and his B.S., Accounting, from Loyola Marymount University.
John T. Woodruff is a partner in the law firm of McDermott Will & Emery LLPand is based in the Firm’s Houston office. John advises clients on all aspects of international tax, transfer pricing, and tax issues related to cross-border mergers, acquisitions and restructurings. He regularly counsels clients on issues related to the U.S. foreign tax credit, subpart F, U.S. trade or business/permanent establishment determinations, treaty-based positions, transfer pricing strategies and strategic tax-related planning for international investments and financings. Drawing on his years of experience in private practice and in major accounting firms, John structures acquisitions, dispositions, public offerings, reorganizations, restructurings, repatriations, and insolvency transactions. He represents multinational clients operating in a broad range of industries, with a particular focus on energy clients involved in exploration and production, oilfield services, offshore drilling, maritime, oilfield manufacturing and engineering, procurement, and construction. John is a regularly featured speaker at conferences, seminars, meetings and other events sponsored by the American Bar Association, the Tax Executives Institute, the American Petroleum Institute, the Houston International Tax Forum, and the CPAmerica Tax Conference, among many other organizations. He has also authored and co-authored articles and online content for a range of legal and industry publications, including Tax Notes International. John is a member of the State Bar of Texas, the State Bar of Virginia, the International Bar Association, the American Bar Association, the Houston Bar Association, the Houston Tax Roundtable, the Houston International Tax Forum and the World Affairs Council of Houston. John is admitted to practice in Texas and Virginia. Mr. Woodruff earned his LL.M. from Georgetown University Law Center; his J.D. from University of Tulsa College of Law and his B.S. from Oklahoma State University.
Steven C. Wrappe is a principal in KPMG’s Economic and Valuation Services practice. He serves as the National Leader for Transfer Pricing Dispute Resolution (TPDR) and the Deputy Head of Global TPDR. Steve splits his time between the firm’s Silicon Valley and McLean Offices. In the nearly two decades prior to joining KPMG, Steve led the APA practice at two other Big Four Firms and was a partner with a global law firm. Before that, Steve served as a senior attorney with the Advance Pricing Agreement Program in the U.S. Internal Revenue Service Office of Associate Chief Counsel (International). Steve has over 30 years of tax experience and 23 years of client and government experience in transfer pricing across all industries and types of transfer pricing issues. Steve’s client service in transfer pricing controversy includes examination, appeals, alternative dispute resolutions, advance pricing agreement (APAs), mutual agreement procedures (MAP) and customs agreements. He is one of the most experienced transfer pricing negotiators anywhere, with a combined APA and MAP experience of more than 150 cases. He represents a number of Fortune 500 clients in transfer pricing disputes. Steve teaches transfer pricing at Georgetown University Law Center, the University of Florida School of Law, and New York University School of Law. He has also taught transfer pricing and transfer pricing controversy at the IRS, U.S. Customs and several other tax authorities. Steve recently published the fourth edition of his leading U.S. transfer pricing treatise (1,100 pages) and has written more than 100 articles on transfer pricing topics. Steve speaks globally with governments and taxpayers on transfer pricing and dispute resolution topics. Steve has served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of New York University School of Law’s International Tax Program and BNA Tax Management (Transfer Pricing). Steve earned his B.B.A. (Accounting) from the University of Notre Dame; his J.D. from the University of Texas School of Law, and his LL.M. from the New York University School of Law.
Raymond P. Wynman is a partner from the Ernst & Young LLP Philadelphia office with more than 15 years of experience in International Tax Services. Mr. Wynman focuses primarily on US international tax planning with particular focus on repatriation planning, foreign tax credit maximization, OFL minimization strategies, post foreign holding company structure maintenance, FMV of apportioning interest expense, modeling merger and acquisition transactions, foreign earnings and profit studies and International tax compliance topics. Mr. Wynman has advised multinational clients on foreign holding company structures, foreign tax planning, cross-border transactions, and Subpart F planning. Mr. Wynman is a frequent speaker on international tax matters. He has addressed the Tax Executive Institute, Networking Seminars and internal Ernst & Young education programs and client seminars. He is a CPA (Pennsylvania) and holds a Master of Taxation and a BSBA (Accounting) degree from Philadelphia University.
David Young joined KPMG in 2011 as a Senior Manager in the International Corporate Services tax practice in New England. Prior to joining KPMG, David was Senior Tax Counsel at Raytheon Company where he led teams responsible for international tax matters and tax quality assurance. David’s prior experience includes, planning and structuring transactions for public and privately held companies as a senior associate in the Tax Practice of Pepper Hamilton LLP and as a senior manager in the Transaction Advisory Services Tax Practice of Ernst & Young LLP. David specializes in international corporate taxation and has over 15 years of experience advising clients on corporate taxation, mergers and acquisitions, and taxation of affiliated and related groups. David’s experience includes assisting multinational corporations with global tax planning, tax efficient global supply chain restructuring, tax efficient repatriation of foreign cash, and global tax controversy. David also has broad experience providing domestic and international tax structuring advice in acquisition transactions. David has worked closely with corporate buyers and sellers on various tax aspects of transactions, including U.S. and foreign tax structuring, obtaining IRS private letter rulings, tax attribute planning, and post-transaction integration. David received his BA in Accounting from The Catholic University of America; his JD from Villanova University School of Law; and his LLM, Taxation from Villanova University School of Law.
Mark Young is a Managing Director with Alvarez & Marsal Taxand, LLC in Houston. He specializes in income tax matters and his primary areas of concentration include federal tax planning, compliance, and financial reporting. Mr. Young has advised multinational companies on income tax matters including tax planning, complex business transactions, compliance and financial reporting matters. In addition to considerable experience in ASC 740 (formerly SFAS 109), he has experience in assisting companies with tax department performance improvement and operations. He has served clients in a variety of industries, including energy, private equity, manufacturing, banking, and insurance. Prior to joining A&M, Mr. Young was with PricewaterhouseCoopers' Industry Service Group and federal tax practice in Houston. Previously, he worked in both Ernst & Young’s Dallas office and the firm’s National Tax Department in Washington, D.C. Mr. Young earned his bachelor’s degree in business, with a concentration in finance, from Washington University in St. Louis. He also earned a law degree from the University of Texas School of Law. Mr. Young is a member of the State Bar of Texas and is a licensed Certified Public Accountant (CPA) in the state of Texas.