Seth Abrams is an International Tax Partner at Deloitte in Houston serving multinational corporations in a variety of industries including energy/power, shipping, refining, manufacturing, oil field services, software/technology and manufacturing/distribution. Seth also has significant experience serving private equity firms with respect to fund level structuring diligence/structuring for acquisitions and dispositions of portfolio companies, and tax efficient financing. Seth has over 11 years of experience advising clients in areas of outbound international taxation, including cross border mergers and acquisitions, tax efficient financing, foreign tax credit planning (including expense apportionment and overall foreign loss planning), initial structuring for new country investments, and repatriation strategies. He has significant experience advising private equity clients in cross border acquisitions and tax efficient financing. Seth also has experience advising clients in certain aspects of inbound international taxation including FIRPTA, earnings stripping, internal restructurings and disposition planning. Seth received his BBA and MPA in accounting from The University of Texas at Austin and is a Certified Public Accountant.
Robert H. Albaral is a Tax Partner at Baker & McKenzie in Dallas, TX. Mr. Albaral routinely represents taxpayers at various stages of state and federal income tax controversies, including audit, administrative appeals and judicial proceedings. His professional affiliations include the American Bar Association, the State Bar of Texas, the US Tax Court, the Federal District Court of Northern District of Texas, the United State Bankruptcy Court, Northern District of Texas, as well as Courts of Appeals. Mr. Albaral regularly assists clients in the resolution of tax through administrative audit and appeals, and if necessary, through litigation. His practice also covers the resolution of domestic and international issues through alternative dispute resolution tools including Fast Track Settlement, Appeals Mediation and Early Referrals to Appeals.
J. Robert Arthur is a principal at ParenteBeard LLC in Philadelphia and has many years of experience in international tax matters. He left a Big Four firm and joined the firm in July 2003. He brought with him a diversified background and significant experience and expertise in global tax planning and analysis. Rob works with clients in a variety of industries including pharmaceuticals, food, electronics and communications, banking and industrial markets. His areas of expertise include: formulating tax-efficient business structures for U.S. companies going overseas or foreign companies coming into the U.S.; completing proactive transfer price studies, identifying business motivated cross-border financing strategies; helping U.S. persons navigate through the U.S. anti-deferral provisions related to controlled foreign corporations and passive foreign investment companies; coordinating the delivery of global tax services; identifying earnings and profits and foreign tax credit planning opportunities; assisting companies develop global reporting packages; and providing due diligence assistance related to foreign mergers and acquisitions. Rob received his Bachelor of Arts degree in History from Susquehanna University.
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.
Kristy Balkwill is an associate with the tax group at Baker & McKenzie in Toronto, specializing in trusts, estates, voluntary disclosures, international tax planning, structuring and litigation. As an associate, Kristy spent two months at the Baker & McKenzie Geneva office, working in the Global Wealth Management Practice Group, and more recently working in the Zurich office of Baker & McKenzie. Kristy is admitted as both a barrister and solicitor in Canada and obtained her J.D. from Queen’s Law, and her LL.M. (Tax) from Osgoode Hall Law School.
Arjun Banerjee is a Manager in the International Tax Services practice in the New York office of PricewaterhouseCoopers LLP. Arjun is in the Quantitative Solutions (QS) practice, a group within the ITS practice that specializes in providing quantitative tax services to multinational companies. Arjun frequently works with multinational companies, in a wide variety of industries, to assist them with managing the cash and effective tax rate impact of pending changes to the U.S. international tax laws and other contemplated planning transactions. Arjun delivers large-scale projects for multinational companies including E&P analyses, foreign stock basis studies, foreign deferred tax studies, branch/disregarded entity FX analyses, Subpart F studies, foreign tax credit and OFL computations, expense allocation studies, international tax reporting and export incentive computations. Arjun received a Bachelor of Science Degree from DeSales University with a dual Major in Accounting and Management of Information Technology. He holds the Certified Public Accountant designation and is a member of the American Institute of Certified Public Accountants.
Yosef Barbut is a director at PricewaterhouseCoopers National Accounting Office. 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.
In the 19 years since completing his Ph.D. from the Wharton School, Dr. Brian C. Becker has produced more than 400 economic expert reports for Fortune 500 corporations, international law firms, the Internal Revenue Service, the Australian Taxation Office and the Canada Revenue Agency. Focusing on transfer pricing, valuation, intellectual property valuation, and damages computations, Dr. Becker has provided testimony in a number of legal venues, including U.S. Tax Court, The Tax Court of Canada, The U.S. Supreme Court, and The Federal Court of Australia. Within transfer pricing, this has included serving as a lead expert witness in the Glaxo dispute in the United States, the GE guarantee dispute in Canada, the McKesson receivables financing dispute in Canada, and disputes involving products/intangibles in Roche and SNF in Australia. In addition to this expert witness experience, Dr. Becker has: (a) published more than two dozen papers/book chapters; and (b) served as a Visiting Professor in the business schools of four universities. Dr. Becker earned M.A. and Ph.D. degrees in Applied Economics from the Wharton School of the University of Pennsylvania. He earned a B.A. in Applied Mathematics and Economics from the Johns Hopkins University.
Roy Berg has more than 19 years experience in tax controversy, cross-border tax matters, estate planning, and finance and has been admitted to the bar associations of the U.S. Tax Court, California and Washington. Prior to the joining Moodys LLP Tax Advisors he worked for Ernst & Young and was General Counsel to PitchBook Data, the premier provider of data and analytics for the private equity industry. In addition, Roy is a frequent writer and speaker on tax controversy, regulation, cross-border, and estate planning issues, in particular. Offshore Voluntary Disclosure Initiative (OVDI): Report of Foreign Bank and Financial Accounts (FBAR/ Form TD F 90-22.1); Foreign Trusts and filing of Forms 3520 and 3520-A; Foreign Entity filings including Forms 5471, 5472, 926, and 8865; Hiring Incentives to Retain Employment Act (HIRE Act); and Foreign Account Tax Compliance Act (FATCA). Roy also has experience in public service; the governor for the State of Washington appointed him to the board of directors of the Washington Economic Development Finance Authority, and has been appointed to the Legislative Committee of the Washington State Bar Association. Roy received a B.A. in Economics from the University of California Berkeley, a J.D. cum laude jointly from Willamette University College of Law and New York University School of law; and his LL.M(Taxation) from New York University School of Law. As an undergraduate Roy was a member of the University of California Berkeley’s intercollegiate swim team.
Matt Billings is a transfer pricing partner at PricewaterhouseCoopers LLP who works with Canadian and foreign-based multinationals, in a variety of industries. He has over 11 years of transfer pricing experience, including 8 in Toronto and 3 in Australia. Matt takes a client-centric approach, with the goal of developing long-term business relationships. His experience includes leading projects for transfer pricing planning, business restructuring, dispute resolution, and the pricing of financial transactions. Matt has also developed niche expertise in areas such as uncertain tax positions related to transfer pricing, the interaction between debt pricing and thin capitalization rules, and the pricing of employee share plan recharges. Born in Fredericton, New Brunswick, Matt earned a Master of Arts in economics from Queen's University, with dual concentrations in international economics and financial economics. He also has a Bachelor of Business Administration from the University of New Brunswick, with a major in economics and a concentration in international business.
Devon M. Bodoh is a principal in KPMG’s Washington National Tax Corporate practice. Mr. Bodoh advises KPMG partners, employees and clients on corporate tax matters including domestic and international mergers, acquisitions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses and other tax attributes, and consolidated return matters. Prior to joining KPMG, Mr. Bodoh was a partner in the international law firm of Dewey & LeBoeuf LLP. Mr. Bodoh is a frequent speaker on federal income tax issues relating to domestic and international mergers and acquisitions, spin-offs and other divestiture strategies, corporate tax planning, workouts, and consolidated return matters for various groups. Mr. Bodoh is a former chairperson and vice-chairperson of the American Bar Association's Committee on Affiliated and Related Corporations. In addition, Mr. Bodoh is a member of the Dean's Advisory Board for the University of Detroit School of Law.
Joel Boff, CPA, is a partner and the New York Tax Practice Director for J.H. Cohn, as well as a member of the Retail, Apparel and Consumer Products Industry Practice. Joel has served clients in industries including professional services, manufacturing, retail, apparel and consumer products, distribution, banking and finance. In addition, he has worked with a large New Jersey-based advertising firm, and pharmaceutical marketing and tradeshow clients. Joel has a proactive role in providing efficient compliance services coupled with effective tax planning for J.H. Cohn clients. Joel joined J.H. Cohn after 12 years in the Metro New York Tax Practice of a Big Four accounting firm. He has established a history of servicing both privately-held middle-market companies, as well as public companies throughout the tri-state area. Examples of specific areas in which Joel has consulted with and has provided value to his clients include mergers and acquisitions, assistance with federal and state tax examinations, state and local tax planning, tax due diligence, efficient tax compliance management, net operating loss planning, FAS 109 compliance and review, and most recently, compliance with FIN 48 and applying the Sarbanes-Oxley Act to tax operations. Joel graduated from Dickinson College, cum laude, with a Bachelor of Arts degree in Economics and from Rutgers University Graduate School of Management with a Master of Business Administration degree in Professional Accounting. He is a certified public accountant in the state of New Jersey, and a member of both the American Institute of Certified Public Accountants and the New Jersey Society of Certified Public Accountants. Joel is also an active member of the Rutgers University Graduate School of Management Tax Advisory Board.
Salvador M. Borraccia is a Partner at Baker & McKenzie LLP in Toronto. Mr. Borraccia Has acted as trial and appellate counsel on a wide variety of matters before the Tax Court of Canada, the Federal Court and the Federal Court of Appeal including through the audit and administrative appeals process and in competent authority negotiations under Canada’s tax treaties. Mr. Borraccia has represented taxpayers in negotiations for advance income tax rulings and advance pricing agreements. In addition to acting as tax counsel, practice focuses on corporate and international tax issues, in particular as they affect the multinational corporation. These include transfer pricing, corporate reorganization, corporate finance, e-commerce and structuring foreign investment in and out of Canada. He is a member of the Law Society of Upper Canada; Canadian Bar Association; Canadian Tax Foundation; International Fiscal Association. Mr. Borraccia was admitted to practice law in Ontario in 1973. Mr. Borraccia is a graduate of Osgoode Hall Law School; Queen’s University and the University of Toronto.
Greg Bryant is a Certified Public Accountant and an attorney with over 25 years of experience in federal and international tax. As a Tax Partner with Williams Mullen, he helps closely held, mid-market and large businesses manage the tax risk, after-tax cash flow, and tax accounting concerns related to domestic and international tax issues. Greg provides in-depth tax planning assistance to companies that are expanding into new markets and confronting complex transfer pricing, structuring and tax accounting issues. He negotiates drafts and deploys multinational supply chain framework agreements, structures international supply chain networks and leverages the value chain of companies to reduce tax risk and improve cash flow. Before joining Williams Mullen, Greg was the national director of value chain transformation for a Big 4 firm. Greg also previously served as vice president of taxes for Alliance One International, a leading international tobacco merchant. He oversaw the company’s expansion into 50 countries throughout Asia, Africa and South America. Greg earned his Accounting degree and Juris Doctor from the University of South Carolina. He has his Master of Laws in Taxation from Georgetown University Law Center. Greg is licensed as a CPA in Maryland and Illinois, and is a member of the American Institute of Certified Public Accountants (AICPA) and the International Fiscal Association (IFA).
Brandon Carbullido is a Manager in Ernst & Young LLP’s International Tax Services practice in San Diego. Brandon assists multinational clients with international tax planning and compliance, with an emphasis on subpart F income, foreign tax credits, entity and debt structuring, intellectual property, and cross border mergers & acquisitions. With over five years of public accounting experience, Brandon has served various clients in the technology, pharmaceutical, telecommunications manufacturing, transportation, consumer products, and financial services industries. Brandon received his J.D. and B.S. in Operations & Management Information Systems from Santa Clara University. He is a member of the State Bar of California and Guam Bar Association.
Sara K. Cerreta is a Manager in Ernst & Young’s International Tax Services Group (“ITS”) in Chicago with almost six years of tax experience where she provides tax services to U.S. and foreign-based multinational companies. Her ITS experience includes International Compliance (Forms 1118, 5471, 8865, and 8858), FMV of Interest Expense Apportionment studies, Earnings and Profits studies, Basis studies, and various other FTC planning projects. Sara also has income tax provision experience on several multinational clients in a variety of industries. Sara has a Bachelor of Business Administration and a Master of Science in Accountancy from the University of Notre Dame. She is CPA licensed in the state of Illinois.
Paul Chmiel is a member of Ernst & Young LLP’s National Transfer Pricing group located in New York and Iselin. Having been with the firm for more than ten years, he focuses on valuation in the pharmaceutical and distribution industries. He also has extensive experiences in dealing with several major telecommunication companies. Paul’s experience has been in the context of tax efficient intangible migration planning; resolution of tax audit controversies with the IRS at the field audit, appeals and competent authority levels; advance pricing agreements; cost sharing and intercompany service arrangements. Paul served 33 years at the Internal Revenue Service that included 28 years in the IRS’ New Jersey office international arena with a specific focus on the complex examination of the major pharmaceutical companies. He was the first transfer pricing issue specialist for the nation responsible for developing consistent transfer pricing positions throughout the US. He was also a representative on a team that wrote the 482 Regulations, including the proposed, temporary and final regulations. Paul participated in the most complex APA cases as a technical specialist and assisted in competent authority negotiations. Paul has a B.A. in Accounting from Seton Hall University.
Kenneth P. Christman, Jr. is a member of Ernst & Young LLP’s International Tax Services (ITS) Transfer Pricing group in Washington D.C. Ken advises clients on transfer pricing controversy and risk management, planning and structuring with a particular emphasis on cross-border transfers of intellectual property and provision of financial services. Ken has significant experience with Advance Pricing Agreements dealing with both intellectual property transfers and financial services. He has worked extensively on cost sharing arrangements involving both technology and industrial corporations and with private equity funds investing in technology, biotechnology and pharmaceutical companies. Prior to joining Ernst & Young LLP, Ken was an attorney with the Internal Revenue Service in Branch 6 (the transfer pricing branch) and Branch 5 (the financial products branch) in the office of Associate Chief Counsel (International) and, prior to that, in the office of Associate Chief Counsel (Financial Institutions and Products). During that time, Ken provided technical support and training to the IRS’s Advance Pricing Agreement Program. He was also the principal author of numerous regulations, including Treas. Reg. §1.482-7T (Taxation of Cost Sharing Arrangements), and of other types of published guidance. Ken was also a member of the IRS’s (Tier I) Cost Sharing Issue Management Team and as well as several Technical Advisory Teams dealing with financial institutions and products. During his time with the IRS, Ken was the recipient of numerous awards including the Department of Treasury’s Legal Division Award for Outstanding Legal Support and the Office of Chief Counsel’s National Litigation Award and National Technical Guidance Award. Ken received his A.B., magna cum laude, Phi Beta Kappa, from Princeton University, his J.D. from Yale Law School and an LL.M. (taxation) from NYU Law School. He is a former editor of the Yale Law Journal and of the Yale Journal of Regulation.
Erik Christenson is a partner at Baker & McKenzie in San Francisco, CA. He practices in the area of general tax planning. He has more than nine years of experience representing multinational corporations — both US and foreign-based — in business taxation matters. He has also worked on significant pro bono matters, including applications for tax exempt status for various charitable organizations. Mr. Christenson advises on all aspects of the taxation of cross-border transactions and operations for clients in various industries, including semiconductor, software, online services and e-commerce, biotechnology and consumer products. Erik Has implemented and restructured complex intellectual property arrangements; developed procedures with respect to manufacturing practices and distribution supply chains; advised on cross-border merger and acquisition transactions; managed several large post-acquisition integrations and other legal entity restructurings through spin-offs, divestitures and joint ventures; developed strategies to repatriate cash or to borrow funds to meet US and non-US cash needs; developed solutions for a wide variety of US and multijurisdictional international tax issues. Erik received his J.D., cum laude from the University of California, Hastings College of the Law and his B.A., cum laude from Dartmouth College.
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.
Maria T.S. Collman is a director at PricewaterhouseCoopers LLP and has 11 years of experience serving oil and gas industry clients with domestic and international tax matters. She is an Energy Industry Tax Director in the Houston office and is an industry representative for alternative energy tax incentives and credits. Maria provides domestic and international tax advice and has experience working with a variety of companies in the energy industry. Her broad industry experience includes significant work with independents, refiners, offshore drillers, oilfield service companies, integrated oil and gas companies, foreign-based companies investing in the U.S. energy market, MLPs, royalty trusts, private-equity funds with investments in oil and gas ventures, and utilities. Maria has also recently begun working with a variety of alternative energy companies (wind, geothermal, and biofuels). Maria's technical experience includes managing federal, state and international compliance; foreign income tax creditability analyses; oil and gas partnership structuring and compliance; income tax accounting; IRS audit defense and protest writing; international reorganizations; tax credit studies; capital cost recovery studies; and tax opinion drafting. Maria is a member of the AICPA tax section and the Texas CPA Society. Maria is a frequent contributor for the Recent Cases, Regulations and Rulings section of the Oil, Gas and Energy Quarterly. She has spoken to the Tax Executives Institute, the Texas Society of CPAs, and the American Petroleum Institute on energy industry tax topics. Maria received her B.B.A., double major in Accounting and Latin American and Iberian Studies from the University of Wisconsin-Madison.
Brian Cromwell is a Transfer Pricing Principal based in the Ernst & Young Pacific Northwest ITS practice. In his many years of experience, Brian has served as the lead economist for major tax integration and restructuring projects for large global multinational companies located in the Western portion of the United States, as well as in other parts of the country. He has experience in virtually all segments of the technology industry, as well as in the life sciences industry and has a national reputation as a very senior transfer pricing advisor. Brian's transfer pricing experience includes controversy support, audit defense, intangible asset valuation, Advance Pricing Agreements, and the design and implementation of global transfer pricing strategies. He has extensive experience in the evaluation, support and defense of intangible pricing positions as part of tax controversy and FIN 48 reviews. Before joining Ernst & Young in July 2009, Brian served as a Principal Economist with Baker & McKenzie Consulting LLC, and was a Principal and founding member of The Ballentine Barbera Group LLC, an economics consulting practice subsequently acquired by Charles Rivers Associates, Inc. He also has previous Big Four experience and served as an Economist with the Federal Reserve Bank of San Francisco and the Federal Reserve Bank of Cleveland. Brian is a frequent speaker at technology industry conferences. He has also served as a Lecturer at the University of California, Berkeley, Haas School of Business. Brian holds a PhD. in Economics from Massachusetts Institute of Technology, and a B.A. in Economics from Swarthmore College.
Andrew Crousore is a Partner at Baker & McKenzie LLP in Palo Alto. Mr. Crousore practices in the area of corporate tax law, with an emphasis on tax controversies, which involve issues ranging from transfer pricing to the research and development credit. While at Baker & McKenzie, Mr. Crousore has participated in the following tax litigation cases: Seagate Technology, Inc. v. Commissioner, T.C. Memo 2000-388 (2000), T.C. Memo 2000-361 (2000); Electronic Arts, Inc. v. Commissioner, 118 T.C. No. 13 (2002); Adobe Systems, Inc. v. Commissioner, T.C. No. 3444-01; Autodesk, Inc. v. Commissioner, T.C. No. 23079-97; Veritas Software Corporation & Subsidiaries, Symantec Corporation (Successor in Interest to Veritas Software Corporation & Subsidiaries) v. Commissioner, T.C. No. 12075-06. Prior to joining Baker & McKenzie in 1998, Mr. Crousore was a member of the Internal Revenue Service’s District Counsel office. He participated as lead trial attorney in cases involving a variety of domestic and international issues in the United States Tax Court. Mr. Crousore also provided legal analysis and advice to IRS auditors and international examiners during tax audits. During his tenure as counsel for the IRS, Mr. Crousore litigated the following cases: Amdahl Corporation v. Commissioner, 108 T.C. 507 (1997); Ghalardi Income Tax Education Foundation v. Commissioner, T.C. Memo 1998-460; Beretta v. Commissioner, T.C. Memo 1997-570; Fraser v. Commissioner, T.C. Memo 1997-18 2; Miller v. Commissioner, T.C. Memo 1997-134; Yei v. Commissioner, T.C. Memo 1997-57; Ghadiri v. Commissioner, T.C. Memo 1996-528; Yates v. Commissioner, T.C. Memo 1996-499. Mr. Crousore received his LL.M. in Taxation from Georgetown University; his J.D. from Ohio Northern University Pettit College of Law; and his B.A. in Economics from Wabash College.
Brendan Cox is a partner in the East Central Sub Area Federal Tax Practice at Ernst & Young LLP, 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.
Brian A. Cromwell is a Transfer Pricing Principal based in the Ernst & Young Pacific Northwest ITS practice. In his many years of experience, Brian has served as the lead economist for major tax integration and restructuring projects for large global multinational companies located in the Western portion of the United States, as well as in other parts of the country. He has experience in virtually all segments of the technology industry, as well as in the life sciences industry and has a national reputation as a very senior transfer pricing advisor. Brian's transfer pricing experience includes controversy support, audit defense, intangible asset valuation, Advance Pricing Agreements, and the design and implementation of global transfer pricing strategies. He has extensive experience in the evaluation, support and defense of intangible pricing positions as part of tax controversy and FIN 48 reviews. Before joining Ernst & Young in July 2009, Brian served as a Principal Economist with Baker & McKenzie Consulting LLC, and was a Principal and founding member of The Ballentine Barbera Group LLC, an economics consulting practice subsequently acquired by Charles Rivers Associates, Inc. He also has previous Big Four experience and served as an Economist with the Federal Reserve Bank of San Francisco and the Federal Reserve Bank of Cleveland. Brian is a frequent speaker at technology industry conferences. He has also served as a Lecturer at the University of California, Berkeley, and Haas School of Business. Brian holds a PhD. in Economics from Massachusetts Institute of Technology, and a B.A. in Economics from Swarthmore College.
Brittain Cunningham is international tax manager at Ernst & Young LLP in Houston, TX. He is a CPA with over 8 years of experience in corporate and international tax. He has managed numerous tax planning and tax restructuring projects including repatriations, mergers/acquisitions, financing structures and the maximization of foreign tax credits. In addition to tax planning, he has deep tax compliance, tax software systems and tax provision experience. He aims to exceed clients’ expectations by delivering expert international tax advice that takes into consideration all impacts of tax planning on business operations, financial statements and tax compliance processes. His experience includes tax compliance and tax restructuring projects for companies from the energy, oil & gas, retail and technology industries. Brittain holds a Master of Tax and a Bachelor of Business Administration from Texas A&M University.
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.
Justin Denworth is a director in PricewaterhouseCoopers International Tax Services practice in San Jose, CA. Justin has over 8 years of experience advising U.S. and foreign multinational corporations on a wide variety of international tax matters. Justin assists companies with modelling to manage the cash and effective tax rate impact of pending changes to U.S. international tax laws and other contemplated planning transactions. Justin also manages large scale and detailed projects for multinational companies including: E&P, Subpart-F, and tax basis computations; reorganization, acquisition, and disposition planning; annual computations for distribution planning; preparation of related reporting; foreign tax credit computations; IRC Sec. 861, Export Incentive & §199 computations and analyses; IRC Sec. 986(c), 987, and 988 computations; and homeland repatriation feasibility studies. Justin prepares and reviews international tax provisions associated with foreign income inclusions. He also designs, orchestrates, and leads numerous national and regional training sessions varying from basic to complex International Tax topics. Justin has a B.S. in International Finance and Management from Fordham University.
Michael C. Durst has extensive experience planning and implementing transfer pricing strategies in the financial services sector and other industries. He also has deep experience defending transfer pricing strategies through audit and appeals, having worked on a large number of matters with both the US government and foreign governments. Mr. Durst served for several years as director of the IRS' Advance Pricing Agreement Program, where he headed a prominent alternative dispute resolution program focused on transfer pricing issues. Mr. Durst is a former counsel of Steptoe & Johnson LLP, where he was a member of the tax practice. Through a continuing strategic alliance with the practice, Mr. Durst, provides international tax and transfer pricing counsel to clients of the firm. While at Steptoe, Mr. Durst was consistently ranked as a leading transfer pricing adviser and tax controversy lawyer in publications such as Legal 500, Guide to the World’s Leading Tax Advisers, Euromoney’s Expert Guide to the Best of the Best, and Best Lawyers in America. Prior to Steptoe, Mr. Durst was at PricewaterhouseCoopers LLP, where he served as a partner in a senior client service and thought leadership capacity within the firm's international tax practice. He also ensured compliance with standards of practice there. Mr. Durst was also a partner in another Washington law firm, where he concentrated on international tax, transfer pricing, tax, and tax-related controversies. Mr. Durst is a frequent author and speaker to professional audiences on transfer pricing and other tax subjects. He has also held numerous positions teaching tax at the law school level at Harvard Law School, Notre Dame Law School, Northwestern University Law School, and Georgetown University Law School. Mr. Durst holds a LL.M. from Harvard University; a J.D. from University of California, Berkeley School of Law; an M.S. in Economics from Massachusettes Institute of Technology, and a B.A. from Williams College. He is admitted to practice in the District of Columbia.
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.
Lucia Fedina is a Director at Deutsche Bank LLP in New York. Over the past 11 years, Lucia has providing transfer pricing advice in the New York area. Lucia specializes in transactions that involve services and intangibles. She has worked with clients in financial services, Pharmaceutical, Chemical and other industries on projects related to planning, audit defense, APA, Fin 48 Reserves and documentation. Currently, Lucia is a KPMG Global Coordinator for provision of Transfer Pricing services related to Investment Management. Examples of Lucia’s prior work include assisting clients in streamlining and simplification of their transfer pricing policies for intangibles and services transactions. The new policies led to efficiency in implementation and significant reduction in yearend adjustments. Lucia has participated in several restructuring projects where she assisted in aligning tax, business and transfer pricing objectives for the clients in luxury, consumer products, banking, insurance and other industries. While in graduate school, Lucia’s research was related to the analysis of exchange rates and present value models. Lucia’s prior work experience includes 2 years as a chemical engineer (during which she obtained a patent for developing a new catalyst for oil refining) and 2 years as a biotech researcher. Lucia holds a Ph.D. in Economics from Ohio State University.
Alan Fischl is an International Tax Partner with PricewaterhouseCoopers LLP’s Washington National Tax Services office. He consults with the firm's practice offices and clients on international tax issues arising in complex transactions, tax planning and controversies with the IRS. Alan has also served as leader of the Washington National Tax Services Energy and Mining Industry practice. Alan has broad experience in international and federal tax matters, including foreign tax credit and related expense allocation issues, issues arising in international mergers, acquisitions and reorganizations and tax treaty issues. He represents clients before the IRS, Treasury and the Congressional tax-writing committees. Prior to joining PricewaterhouseCoopers LLP, Alan was a partner with a Washington, D.C. tax law firm and the Chair of its Tax Department. He was responsible for a variety of tax matters for major multinational clients. Alan was also a legislation attorney with the Congressional Joint Committee on Taxation, where he was a principal participant in the development and drafting of the international provisions of the Tax Reform Act of 1986 and assisted the Senate Foreign Relations Committee in its analysis of proposed income tax treaties. He is a past Chair of the Foreign Activities of US Taxpayers Committee of the American Bar Association Tax Section, and he speaks and writes frequently on international tax issues. He also is a member of the Board of Advisors of the Journal of International Taxation, the Advisory Board of Tax Management International Journal, the AICPA International Tax Technical Resources Panel, and the American Law Institute. Alan earned a JD cum laude from Harvard Law School in 1980 and an AB magna cum laude and Phi Beta Kappa from Brandeis University in 1977. He is a member of the District of Columbia Bar and the New York Bar.
Tim Fitzgibbon is a Director in the International Tax Services group of PricewaterhouseCoopers LLP 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.
Paul Flignor, Principal Economist with DLA Piper's Tax group based in Chicago, concentrates his practice in intercompany pricing and intellectual property valuation. He has more than 15 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. Before coming to DLA Piper, Mr. Flignor was a partner with PricewaterhouseCooper's valuation and transfer pricing practice, where he led the transfer pricing automotive industry efforts. For several years, he also was a principal in the strategy and economic consulting practice at A. T. Kearney, a leading international management consulting firm.He is an adjunct professor at Northwestern University, where he teaches courses in corporate value chain management. Paul received his M.B.A. in Finance from The University of Chicago and his A.B. in Economics from The University of Chicago.
Sean Foley is the National Leader for KPMG’s U.S. Transfer Pricing Practice and the head of KPMG’s Global Transfer Pricing Services Americas Region. He is based in Washington, DC. Sean has over fifteen years of experience in analyzing the intercompany transactions for major multinational corporations. Sean’s primary areas of focus include Advance Pricing Agreements and Competent Authority matters and transfer pricing risk management. Prior to joining KPMG, Sean was the Director of the Advance Pricing Agreement (APA) Program of the Internal Revenue Service in Washington, DC, from 2000 through 2002. From 1997 to 2000, Sean was Special Counsel to the IRS Associate Chief Counsel (International) where he participated as a front office reviewer in a variety of international regulation and technical advice projects. Before joining the IRS, Sean was an associate with the Washington, DC Firm of Covington & Burling. Sean clerked for Justice Ruth Bader Ginsburg when she sat on the DC Circuit. Sean also served as Legislative Assistant, and then Legislative Director, to Congressman Sander M. Levin, a member of the House Ways and Means Committee. Sean has an LL.M. (Taxation) with distinction from the Georgetown University Law Center, a J.D. summa cum laude from Georgetown University Law Center, and a B.S. from the University of Michigan. From 2005 to 2007, Sean was an Adjunct Professor in the Georgetown University Law Center LL.M. program where he taught advanced transfer pricing. He is currently the Vice-chair of the American Bar Association Transfer Pricing Committee. Sean authors a monthly column for the International Tax Review on U.S. international tax developments and is the author of a number of articles on transfer pricing. Sean is the recipient of the 2001 IRS Chief Counsel Manager of the Year Award (Langdon Award) and 2002 Associate Chief Counsel (International) Award for Extraordinary Service.
Stephen C. Fox, CPA, CMA, advises clients, including CPA firms and business entities, on international tax matters. Steve is a Certified Public Accountant and Certified Management Accountant with over 30 years tax experience, primarily in international tax. Mr. Fox has advised clients in a wide array of industries on international structuring, foreign tax credit issues, intercompany pricing, Subpart F, international assignees, DISCs, Section 199, and inbound issues. He has also directed clients’ tax computerization projects. Steve’s clients have included AT&T, Lucent, TransTechnology, Dialogic, Carbone Lorraine, Konica, Steelcase, Interface, Brighton-Best, K&F, MetTel, 1-4 Group, and others. He is a frequent lecturer with professional tax organizations, and has authored articles appearing in Journal of Taxation, Journal of International Taxation, and other publications. As Adjunct Professor of Taxation at Fairleigh Dickinson University he developed their international tax program. Steve previously served as an International Tax Director with national CPA firms.
Shane Frazier is a member of Ernst & Young LLP’s International Tax Services practice in Chicago, IL. Shane has approximately thirteen years of experience providing international tax consulting services to US and foreign corporate clients and has advised them on a variety of issues in both an inbound and outbound context. With respect to US inbound, Shane has worked on a varietyof issues including treaty analysis, cash repatriation, withholding tax planning, structuring /restructuring, debt and equity financing, and withholding and income tax compliance. With respect to US outbound, Shane has advised companies on issues related to US and foreign tax compliance, transfer pricing, foreign tax credit planning, international acquisitions/dispositions/reorganizations, cash repatriation, financing, Subpart F planning, and other tax planning strategies to manage a company’s effective tax rate. Prior to joining Ernst & Young LLP, Shane worked as an International Tax Consultant for another Big Four accounting firm in Minneapolis, Milwaukee, and London, England, where he participated in a two-year assignment developing and managing the firm’s global database of international tax planning ideas. Prior to joining Ernst & Young LLP, Shane worked as an International Tax Consultant for another Big Four accounting firm in Minneapolis, Milwaukee, and London, England, where he participated in a two-year assignment developing and managing the firm’s global database of international tax planning ideas. Shane received his Juris Doctor, cum laude, from the University of Minnesota Law School. He is a licensed attorney in the State of Minnesota.
Gabriel Fuentes is an Executive Director at Ernst & Young LLP in Dallas, Texas. Gabriel assists multinational organizations with global transfer pricing planning, supply chain practices, local and regional documentation projects, and local country controversy issues. Gabriel’s experience includes working on the domestic and international transfer pricing issues of multinationals in the following industries: transportation, consumer goods, telecommunications, mining, and oil-field services. Prior to joining our Dallas office, Gabriel served as the Transfer Pricing Practice Leader for the associated firms of Ernst & Young LLP in the South America region. In that role, Gabriel assisted multinational organizations in coordinating their transfer pricing needs in Latin America. Gabriel has over nine years of experience in Transfer Pricing with Ernst & Young. Gabriel received a Ph.D. in Economics from the University of California, Berkeley in 1994. Prior to joining Ernst & Young, Gabriel was an Associate Professor of Economics at Loyola Marymount University in Los Angeles, California.
Maureen Garcia is an Executive Director in the International Tax Services Group at Ernst & Young LLP in Chicago. Maureen has over 17 years experience in the international tax area. Maureen serves as the Midwest Sub Area (MWSA) International Tax Outsourcing/Operations (ITO) Practice leader, as well as, the MWSA Ops/ITS Liaison. Maureen is an Ernst & Young resource heavily utilized for quantitative international tax planning and is involved in foreign tax credit utilization planning, international tax compliance, IRS Audit defense, earnings and profits studies, and computing the Dollar Approximate Separate Transaction Method (DASTM) of earnings and profits. She has also been involved in merger and acquisition restructuring of foreign operations of U.S. based multinationals including: due diligence, implementation, and data collection. She has experience with various Foreign Tax Credit software systems including: OneSource RS International, ITMS/FTMS and CorpTax - International. Maureen has earned not only a BS in Accountancy, but also an MS in Taxation, both from the University of Illinois at Urbana-Champaign. In addition, she is a CPA. Maureen has been an internal and external lecturer at international tax education seminars in the Chicago area.
Steven Garden is an associate in the Tax Transactions group at Mayer Brown in the Chicago. Steven represents clients on a wide range of tax matters, including mergers, acquisitions, and dispositions of businesses, domestic and international corporate structure planning and restructuring, securities offerings, structured finance transactions, real estate investment trusts (REITs) and cross-border transactions (such as outbound investment and operation in foreign jurisdictions and foreign investment in the United States including under the Foreign Investment Real Property Tax Act (FIRPTA)). Steven joined Mayer Brown in 2007. Steve earned his LLM in Taxation from Northwestern University School of Law LLM in Taxation, with honors ; Chicago-Kent College of Law, Illinois Institute of Technology, JD, with honors, Senior Associate, Chicago-Kent Law Review, Dean's List; Hebrew Theological College, BA, with high honors, Dean's List.
Neil Gerard, CPA, is a tax partner at J.H. Cohn with over 16 years of diversified public accounting experience. Neil is the ASC 740 and ASC740-10 Group Leader and a member of the Firm’s Manufacturing and Distribution Industry Practice, working with public and private middle market and large multinational clients. Specializing in providing tax services to clients in various industries, Neil assists in reviewing and preparing multinational tax provisions and related disclosures in accordance with ASC 740 (formerly FAS 109), implementation and review of ASC 740-10 (formerly FIN 48) Accounting for Uncertain Tax Positions, and internal control testing of tax provisions. In addition, he assists in implementing and documenting internal controls for Sarbanes-Oxley Section 404 compliance, accounting methods reviews, state and local tax analysis, and review and preparation of federal consolidated tax returns. Neil also provides tax consulting services to both public and private clients in the pharmaceutical, chemical, consumer products, and service industries. Before joining J.H. Cohn, Neil worked for two top international accounting firms on tax compliance and tax consulting services. Neil received his Bachelor of Science degree in Accounting from Rider University. Currently, he is working towards completing his Master of Arts in Taxation from Fairleigh Dickinson University. Neil is a member of the American Institute of Certified Public Accountants and the New Jersey Society of Certified Public Accountants. He also serves on the Accounting Advisory Board of Rider University.
Rick Giolitti is a partner in PricewaterhouseCoopers International Tax Services group in San Francisco. Rick has over ten years experience in PwC’s international tax practice consulting clients on U.S. and foreign tax planning for international operations and foreign clients on U.S. and foreign tax planning with respect to investing and conducting operations in the U.S. Rick has significant experience working with U.S. clients in connection with outbound investing throughout Europe, Asia and the Americas, including acquisition diligence and integration, structuring foreign operations, foreign tax credit planning and planning to manage subpart F Rick also consults with U.S. and foreign clients with respect to inbound investing, including planning for effectively connected income, withholding, and related compliance. Rick also has significant FAS 109 experience with respect to cross boarder operations. Rick received his B.A. from University of California at Los Angeles in 1994, J.D. from the University of Oregon in 1997, and LL.M. in taxation from Georgetown University Law Center in 1998. Rick is a member of the California Bar Association.
Carlos M. Gonzalez is a Tax Partner in KPMG’s Philadelphia International Tax practice. He has more than 25 years experience specializing in international tax planning for U.S. and foreign multinational corporations. Mr. Gonzalez primary focus is the U.S. taxation of international operations including subpart f income, repatriation of foreign profits, sourcing of income, international structuring and foreign corporations doing business in the U.S. Mr. Gonzalez has extensive experience designing and implementing tax-efficient corporate structuring of M&A activities (including post-deal structuring), new investments and supply chain analysis. The techniques involve the use of contract and toll manufacturing, sales and purchase commissions, holding and finance companies, debt push-down, and other tax advantaged structures. Mr. Gonzalez is a board member for the British American Business Council and the International Fiscal Association. Mr. Gonzalez received his BS in Accounting (summa cum laude) from Winthrop University, his MS in Taxation from Virginia Polytechnic Institute. He is a CPA in Pennsylvania and Florida.
Lewis J. Greenwald is a U.S. international tax partner in the Tax Department at Sullivan & Worcester in Boston. Prior to joining Sullivan & Worcester, Mr. Greenwald was a partner in the International Tax Services Department in PricewaterhouseCoopers’ Boston office. His practice is focused on providing international tax planning for multinational clients. Mr. Greenwald has more than 22 years of tax law experience. He has written numerous articles for various international tax journals and he is the regional vice president of the New England Region of The International Fiscal Association (IFA). He is on the Board of the National Foreign Trade Council (NFTC) and on the Board of Advisers for the Journal of International Taxation. Mr. Greenwald received his J.D. from Fordham University School of Law, his M.B.A. from Rutgers University Graduate School of Management and his B.A. from New York University.
Lucie L. Guernsey has had over 25 years of credit, financial and commercial banking experience in the global Media and Entertainment Industries. Her 25 years’ experience encompasses the film, television, cable, broadcasting, music, gaming and publishing industries and her broad expertise includes activities such as Structured Loans, Single Purpose Loans, Mergers and Acquisitions, Private Equity, European Capital Markets, Bank Syndications and Pirate Placements. Ms. Guernsey has had experience in the specialized area of Media and Entertainment in both traditional and investment banking areas. Currently Ms. Guernsey is a Managing Director, USA, at Woodland Bay Capital Ltd, a Vancouver based company organized to arrange for a variety of production services, including arranging for the monetization of Canadian tax rebates for content copyright owners. In addition, Ms. Guernsey is an interim CFO for Nitrogen Studios Canada Ltd, a quality animation studio in Vancouver, and is a consultant to Deloitte, Cayman Islands, where she is working to liquidate a number of entertainment assets in funds managed by Deloitte. Prior to today, Ms. Guernsey was the Chief Investment Officer for the fully allocated Cedar Lane Entertainment Fund. Ms. Guernsey has also worked at IDB Bank’s Entertainment, Sports and Media team. Prior to IDB, Ms. Guernsey ran a global Media and Entertainment Group at WestLB. Prior to WestLB, Ms. Guernsey was at Chemical Bank in their Media and Entertainment Industries division. Ms. Guernsey has spoken at a number of seminars and panel discussions at Columbia University, The New York Film Forum and New York University’s MBA School. Ms. Guernsey was invited and has recently joined the International Executive Resources Group (New York), an organization of senior international business executives.
Stanley J. Hales, Ph.D. is a principal in the transfer pricing group and a senior economist based in the San Francisco office of PricewaterhouseCoopers L.L.P with more than 12 years of transfer pricing experience. Dr. Hales advises multinational and multi-state clients on solutions to transfer pricing and tax related valuation issues, with focus on the financial services industry. His diverse international experience covers the three primary transfer pricing services areas: documentation studies; tax planning studies; and transfer pricing audit defenses. The transfer pricing documentation and planning studies include the preparation of analyses related to various intercompany fees, insurance premia, commissions, credit spreads, guarantees, interest rates, as well as royalty modeling and cost sharing analyses related to intangible property, and cost allocation studies. Dr. Hales audit defense experience has involved defending clients in IRS Appeals meetings; preparing Mutual Agreement Procedure submissions to the IRS, the ATO, and Japanese NTA; preparing rebuttal papers concerning proposed tax adjustments; audit settlement negotiations with the IRS Appeals Office, NTA and ATO regarding transfer pricing audits; and negotiating Advanced Pricing Agreements with revenue authorities. Dr. Hales taught university level courses in economics, statistics, money and banking and transfer pricing. He was a doctoral fellow at the Rheinische Friedrich-Wilhelms-Universität Bonn and earned M.A. and Ph.D. degrees in Economics, Ohio State University of Columbus, Ohio USA, with primary focus on the valuation of foreign currency futures options. Additional relevant transfer pricing experience includes work related to: the implementation of the U.S. Treasury proposed global dealing regulations; the OECD discussion drafts on global trading of financial instruments; the OECD Discussion Draft Reports on the Allocation of Income to Permanent Establishments; and the U.K. Inland Revenue tax bulletin on the taxation of global trading.
Bruce Handa is a member of Ernst & Young LLP’s International Tax Services in San Jose, California. Bruce has over ten years of experience with Ernst & Young LLP with a focus on international tax planning, international tax compliance and quantitative consulting, and accounting for income taxes for a broad range of technology companies. Bruce also has four years of experience as a Senior Tax Manager and Manufacturing Controller for an S&P 500 semiconductor manufacturing equipment company and as a self-employed tax consultant for various technology companies. Bruce has a Masters of Science in Taxation from San Diego State University. He is a certified public accountant licensed in the state of California and is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Benjamin Handler is a senior associate at Skadden, Arps, Slate, Meagher & Flom LLP and represents clients on a wide range of domestic and international tax matters with particular emphasis on mergers and acquisitions, spin-offs, internal restructurings, investment fund formations and operations, and real estate investment trusts (REITs). In recent years, Mr. Handler has advised: Pfizer Inc. in connection with the acquisition and integration of Wyeth; Loews Corporation in connection with the spin-off of Lorillard, Inc. to its Loews; Group and Carolina Group shareholders; BHP Billiton in connection with its proposed $147 billion acquisition of Rio Tinto to name a few. Mr. Handler also regularly advises clients with respect to debt and equity offerings, including Arbor Realty Trust Inc.; Orbitz Worldwide, Inc.; Travelport Limited; J.G. Wentworth Inc.; and Rite Aid Corp. His clients include large multinational corporations, private equity and other investment funds, and corporate executives. Mr. Handler is an author of “Tracking Tracking Stock,” published in Practicing Law Institute’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings. He contributed to the recent revision to Tax Management Portfolio 770, “Structuring Corporate Acquisitions – Tax Aspects.” Mr. Handler currently is pursuing his Masters of Laws in Taxation at New York University. Mr Handler received his J.D. from Columbia University School and his B.A. from Yale University.
Alexander Hanhan is a Tax Manageing Director with the International Corporate Services group in KPMG’s Houston 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 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.
Dr. Rachel Hersey has been practicing international tax law for 20+ years. Dr. Hersey spent the first 12 years of her legal career in Palo Alto, California as an international tax lawyer at the law firms of Fenwick & West LLP and Baker & McKenzie LLP. With a Ph.D. in applied mathematics (in the field of Artificial Intelligence), Dr. Hersey was uniquely qualified to advise high-tech, software and e-commerce companies while practicing in Silicon Valley, and played a pivotal role in the decision taken by the Office of Economic Cooperation and Development (“OECD”) that servers generally should not constitute permanent establishments under the OECD Model Tax Convention. Most recently, Dr. Hersey worked as an Executive Director of International Tax at Grant Thornton LLP and as a Senior Manager of International Tax at Ernst & Young LLP. In these positions, Dr. Hersey was responsible for advising clients from a wide variety of industries on numerous international tax research, planning and compliance matters, including, but not limited to, global withholding tax matters, including withholding under FIRPTA, U.S. transfer pricing under section 482, subpart F income, corporate reorganizations and acquisitions, the formation of foreign holding company structures to afford businesses better cash repatriation and management systems, FBAR reporting, preparing FIN 48 reviews, foreign tax credit studies, earnings and profits studies, and advising clients whether their U.S. activities constituted a U.S. trade or business, and, if so, that person’s U.S. tax filing and payment obligations. Among her many recent successes, Dr. Hersey spearheaded the successful recovery of approximately US$1 million of foreign withholding taxes for one of her client’s. Dr. Hersey has worked extensively with numerous private equity and hedge funds that have significant cross-border investments. Of particular concern to these clients is whether the funds’ profits (whether derived from the sale of securities, swaps, derivatives, or real property) would be subject to local taxation; the funds’ reporting obligations, if any, in the various jurisdictions; the availability of treaty benefits on a flow through basis to members of the fund; and whether in determining the profits of the fund sourced in their jurisdiction, the local tax authorities allow the netting of profits and losses (including loss carryforwards).Dr. Hersey is a member of the California bar and active in several professional associations. Dr. Hersey is a frequent lecturer on international tax topics. Dr. Hersey is the author and coauthor of many articles on various international tax topics including contract manufacturing under subpart F, stock options in cost sharing arrangements, the attribution of profits to permanent establishments, and the interaction between e-commerce transactions and dependent agent contract concluding permanent establishments. Dr. Hersey received her Ph.D. at Harvard University and her J.D. at Stanford University.
Matthew J. Hofheimer is an associate at the Chicago office of the law firm of Skadden, Arps, Slate, Meagher & Flom LLP. His practice concentrates on a broad range of federal income tax planning matters, including tax issues related to mergers and acquisitions, dispositions (including spin-offs and split-offs), financings, reorganizations, restructurings (both in and out of bankruptcy), partnership and joint venture transactions, and preservation and utilization of net operating losses. Matthew received his J.D. from the University of Chicago Law School and his B.A. from Vanderbilt 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.
Fred Johnson is a Partner at KPMG LLP in San Francisco and has more than 20 years of direct experience resolving transfer pricing controversy. Fred is the leader of KPMG’s West Region Advance Pricing Agreement (APA) and Competent Authority practice where he is currently advising over 30 clients with respect to their unilateral and/or bilateral APAs. Prior to joining KPMG, Fred spent 17 years at IRS. Fred’s prior IRS experience includes working at the U.S. Competent Authority office for 10 years, where he was directly responsible for the resolution of some of the highest profile transfer pricing disputes, involving negotiations with Japan, Canada, The Netherlands, Korea and several other treaty partners (primary focus on Japan). Fred also worked as an APA Team Leader. As an IRS International Examiner, Fred performed more than 40 transfer pricing audits on both inbound and outbound transactions. Based on his prior IRS experience, Fred focuses on assisting clients in developing and implementing effective resolution strategies for their unilateral and bilateral APA requests.
Per Juvkam-Wold is a member of Ernst & Young LLP’s National Tax group and is part of the International Tax Services practice. He advises clients primarily on international transfer pricing matters and related tax controversies. Mr. Juvkam-Wold assists clients in resolving tax controversies regarding their intercompany pricing through negotiations with the Internal Revenue Service, including use of advance pricing agreements and competent authority processes. He provides tax planning advice for clients in the treatment of their intercompany transactions, consults on transfer pricing risk analyses, reviews and advises on penalty protection documentation, advises on tax provision analyses, and gives training and informational presentations regarding international tax controversy and transfer pricing matters. Prior to joining Ernst & Young LLP in 2009, Mr. Juvkam-Wold was a Director for Transfer Pricing and Global Dispute Resolution with PricewaterhouseCooper’s Washington National Tax Services group. He also spent seven years as a Team Leader with the IRS Advance Pricing Agreement (APA) Program, where he worked with the cost sharing, financial products and automotive industry teams. Mr. Juvkam-Wold holds a J.D. from the University of Texas School of Law and an Economics S.B. from the Massachusetts Institute of Technology. He is admitted to the bar associations of Texas and the District of Columbia. He is authorized to practice before the IRS.
Vinay Kapoor is a Principal in KPMG’s Economic and Valuation Services practice at KPMG LLP. He is an applied economist with more than 17 years of experience in providing transfer pricing economics, valuation and quantitative consulting services, with a focus on the analysis of intangibles and complicated fact patterns. Prior to joining KPMG in 2011, he led the East Coast transfer pricing practice of a multinational financial advisory and valuation services firm. Vinay has worked with companies in numerous industries on transfer pricing planning and documentation matters, with a significant focus in the technology, industrial and healthcare industries. Highlights of his experience include: Advised a number of software and hardware technology companies on the arm’s length values of intangibles transferred cross-border pursuant to cost sharing arrangements, restructurings and acquisitions/ divestitures/mergers. He served as the principal transfer pricing advisor to one of the larger and more acquisitive software companies on all of its acquisitions, and instituted a number of procedures to assist the company with efficiently preparing “buy-in” calculations. An infrastructure software company made a large acquisition and transferred the acquired IP to a cost sharing arrangement. There were questions regarding which of the acquired company’s subsidiaries owned the IP. Worked closely with the company’s outside tax counsel to undertake a detailed analysis of the historic development of the IP and devised an approach to account for the “mixed” IP ownership. The resulting transfer pricing analysis assisted the company with minimizing significant local country tax exposures. A pharmaceutical company faced tax exposures in a number of countries due to the company’s high profitability and historic lack of attention to transfer pricing. Developed and implemented a transfer pricing policy aligned with the company’s operating model of having multiple “entrepreneurs”, including implementing a revised intangibles licensing structure and revised charges for HQ services. Vinay has published some of his work on transfer pricing in publications such as BNA Transfer Pricing Report, World Finance and Tax Notes International. He has also been an invited speaker at conferences on various transfer pricing issues, and has been quoted by the business press on issues such as cost sharing arrangements and accounting for losses in down cycles. Vinay received his PhD and MA in economics (concentration in finance) from Cornell University and his BA in Economics from Cornell University.
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.
Ashley Kerr is an International Tax Manager at Deloitte serving multinational corporations in a variety of industries including refining, manufacturing, oil field services, and manufacturing/distribution. Ashley also has significant experience serving private equity firms with respect to fund level structuring, acquisitions and dispositions of portfolio companies and tax efficient financing. Ashley has over 5 years of experience advising clients in areas of outbound international taxation, including cross border mergers and acquisitions, foreign tax credit planning (including expense apportionment and overall foreign loss planning), initial structuring for new country investments, and repatriation strategies. She has experience advising private equity clients in cross border acquisitions and tax efficient financing. Ashley received her BBA and MPA in accounting from Texas A&M University and is a Certified Public Accountant.
David Kim is a Senior Manager in KPMG’s Chicago’s International Corporate Services practice. He has more than 10 years of experience in tax planning and structuring of transactions for public and privately held clients. David is responsible for a broad range of U.S. multi-national and foreign-owned clients doing business as single entities or in joint venture, and has extensive experience with a wide range of complex tax matters relating to his clients’ businesses. David’s current and past clients include leaders in the agricultural commodity, biofuel, transportation, steel, and financial services industries. David has advised multinational corporations in planning and implementing international tax strategies. For example: Advise on international tax planning and implementation of complex supply-chain structures that involve multiple foreign jurisdictions; Consult on cross-border financing strategies that include repos and hybrid debt instruments; Advise clients extensively on income tax treaty positions, including several inbound clients on issues from U.S trade/business and PE to withholding tax consequences; Work on international mergers and acquisitions, reorganizations, and holding company structures; Advise clients on international tax consequences of intellectual property transactions, effective foreign tax credit utilization, and implementation of foreign treasury centers; Assist and advise clients on tax controversies, including IRS audits and appeals, concerning international and Sub C issues. Perform final review of draft responses to IDRs, NOPAs and protest briefs.
Kathrine Kimball is a principal with Deloitte LLP in San Diego. Her experience in 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 18 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. Ms. Kimball has recently been named in Euromoney’s 2012 Expert Guide to the World’s Leading Transfer Pricing Advisors.
Frank Landreneau CPA, Director, International Tax Services at Pannell Kerr Forster (PFK) of Texas, P.C. Frank 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.
Connie Lee is an international tax director of Deloitte Tax LLP. She assists multinational and pre-IPO clients with inbound and outbound tax issues, including but not limited to tax treaty analysis, withholding taxes, PE, E&P, accounting methods, and foreign earning repatriation. Connie also provides income tax provision (ASC 740) assistance to clients and has deep knowledge in areas such as outside basis differences, currency transaction/translation rules, intercompany transactions, and business combination (ASC 805).
Kevin Liss is an International Tax Director with PricewaterhouseCoopers LLP’s Washington National Tax Services office. He consults with the firm's practice offices and clients on international tax issues arising in complex transactions, tax planning and controversies with the IRS. He has also published four articles on financial derivative products. Kevin earned an LLM in Taxation from New York University Law School in 1994, a JD from Columbia Law School in 1988, where he was a member of the Columbia Law Review, and a BA magna cum laude and Phi Beta Kappa from Columbia University in 1984. He is a member of the New York Bar.
James C. Lawson, CPA, JD, MST is a Principal in ParenteBeard’s International Tax Practice. With more than 16 years of public accounting experience in corporate and international taxation, Jim serves large and middle market multinational companies, both public and private, across industries. He is highly respected for his expertise in the tax planning, compliance and provision disciplines in matters of U.S. federal and state, U.S. international, and local country tax law. Jim specializes in global tax minimization, repatriation strategies, foreign tax credit management, international tax compliance, and ASC 740 – Accounting for Income Taxes. Additionally, he advises clients on structuring, restructuring, corporate acquisitions, and divestitures, including consultation in tax optimized global supply chain realignment and emerging markets expansion. Jim has complementary experience in transfer pricing matters, and has been a frequent speaker on topics including International Accounting for Income Taxes. Jim has a BS in Business Administration from Thomas Edison State College, a MS in Taxation from Drexel University and a JD from Rutgers University School of Law.
Jeffrey A. Levenstam is an international tax services partner at Ernst & Young LLP based 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.
Darren Lo is a senior manager at Moss Adams LLP in Santa Clara, CA. Darren has been providing transfer pricing consulting to various multinational and middle market companies for over 12 years. He has extensive experience in evaluating and comparing transfer pricing strategies, economic modeling, and providing support for planning and compliance with local transfer pricing rules. Darren has a complete understanding of transactions including intangible property migration buy-ins and cost sharing, transfers of tangible and intangible goods, services, royalties, and loans. He has experience with companies in a wide variety of industries including technology (hardware and software), clothing and apparel, manufacturing and distribution, real estate, aerospace, automotive, food processing, and mining. Prior to joining Moss Adams, Darren spent seven years assisting clients, including several of the top 50 Fortune 500 companies, with transfer pricing that maximizes overall firm profits and optimizes efficient taxation. Prior to that he was a transfer pricing and economic analyst in Australia where his responsibilities included analysis of cross-border transactions, pricing controversy in response to Australian Taxation Office (ATO) information requests and audit position papers, and preparation of “Advance Pricing Agreements” with clients on a bilateral and unilateral basis. Darren is a Chartered Accountant with the Institute of Chartered Accountants in Australia, a member of the American Institute of CPAs (AICPA) and the California Society of Certified Public Accountants.
Jeff Maydew is a partner at Baker & McKenzie LLP. His practice focus is on domestic and international tax planning. Mr. Maydew has more than ten years of experience representing U.S. and foreign-based multinational organizations. His area of expertise is in business taxation, including particularly domestic and international tax planning for mergers, acquisitions and other major corporate transactions. His practice also includes private ruling requests, audit and tax controversy matters. He represents clients in the aerospace, automotive, consumer products, e-commerce, electronics, petrochemicals and other industries. Publications include “New Regulations Address ‘Stockless DS’ and other Reorganizations of Controlled Subsidiaries,” Practical U.S./International Tax Strategies, Vol. 11, No. 4 (February 28, 2007); “IRS Issues Final Regulations on Capitalizing Amounts Paid for Intangibles,” (B&M Tax News and Developments (February 2004); “Recent Developments for Using a Target’s NOLs,” (The Tax Advisor, July 1999). Mr. Maydew has taught courses in International Taxation as an Adjunct Professor at the Georgetown University Law Center LL.M program. Mr. Maydew received his LL.M. from Georgetown University Law Center; his J.D., law review, with honors from University of Iowa College of Law, and his B.S., Phi Beta Kappa from Iowa State University.
Michael J. Masciangelo is a member of Ernst & Young LLP’s International Tax Services practice in Houston. Michael is responsible for coordinating Ernst & Young’s global resources in designing and implementing strategies for our clients. He focuses in the areas of holding company structures, principal company structures, financing structures and related repatriation techniques, foreign tax credits and cross border mergers and acquisitions. Michael has worked with several Ernst & Young offices since joining the firm in 1995 and has over 14 years of experience in corporate and international tax. From 2000 to 2003, he was based in Amsterdam, where he served on the US Tax Desk, working for both US-based and European-based multinational companies. 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 Inbound Tax Market Leader for the Southwest Sub Area. Michael has been actively involved in advising our clients on both internal and external restructurings, financing, acquisitions, joint ventures, foreign tax credit matters and repatriation. He has also been involved with complex tax provision reviews, research of and advising on FAS 109 issues and has extensive experience in advising on matters of foreign source income and expense allocation and application. 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 and is a member of the Texas CPA Society.
Martin Martinez, Shareholder, Tax Services, Fitts Roberts & Co., P.C. Martin has over 20 years of professional experience in tax planning and compliance in both public accounting and industry. His areas of expertise include federal, state and international taxation, tax planning and research. Martin provides specialized support in the areas of research and development (R&D) tax credits and incentives, Section 199 deduction for domestic production activities and tax aspects of accounting for derivatives (ASC Topic 815). He is also the co-tax lead for accounting for income taxes ASC Topic 740 (FAS 109) and FIN 48. As a tax services shareholder, Martin assists both public and private companies with tax consulting services for a wide range of business issues. He has experience in a number of industries including energy, natural resources, manufacturing, oilfield services and construction. Martin seeks first to understand the business drivers and objectives of his clients and then works to deliver tax advice that is both practical and in line with the client’s operations. Before joining Fitts Roberts, Martin was a member of KPMG and worked in the tax departments of Fortune 500 companies. He is a former International Tax Manager for a multi-national energy company. He is currently a member of the American Institute of Certified Public Accountants (AICPA) and the Texas Society of Certified Public Accountants. Martin earned a Bachelor of Business Administration in Accounting degree from the University of Houston.
Enrique MacGregor is Managing Director of the Ceteris regional office in Dallas and was recently honored to be chosen as one of only 20 key tax advisors by readers of the International Tax Review. With a combined industry and consulting experience spanning over 18 years, he has practiced transfer pricing for the past eleven years as the regional leader of Deloitte’s South Central practice and more recently as partner-in-charge of Grant Thornton’s national transfer pricing group. Enrique’s experience includes transfer pricing studies for Section 482 compliance involving intercompany transfers of goods, service fees, migration of intangible assets, and contemporaneous documentation for Section 6662 compliance. He has extensive experience implementing strategies for efficient global management of intangible assets. Enrique holds an MBA from the University of Minnesota’s Curtis Carlson School of Management, and a BS from Texas A&M University.
Kendra M. Massumi is an associate in the Tax Practice Group of Baker & McKenzie's Houston office. Before joining Baker & McKenzie in May 2006, she was with Ernst & Young LLP’s International Tax Services practice in New York. Ms. Massumi is a member of the American Bar Association, Section of Taxation, The State Bar of Texas, the Texas Young Lawyers Association, the Houston Bar Association and The International Tax Forum of Houston. She is also a certified public accountant licensed in the State of Texas. Ms. Massumi helps US-based multinational corporations plan and implement tax-efficient supply chain and financing structures, structure intellectual property ownership and price intercompany transactions. She also advises taxpayers on federal income tax controversies as well as the tax aspects of mergers and acquisitions. Ms. Massumi is experienced with SFAS 109 and FIN 48 requirements for SEC registrants.
Esther Meiersdorf is a CPA based in the Toronto office of KPMG, LLP where she works as a senior manager in the U.S. Corporate Tax Division. Ms. Meiersdorf has recently moved to Canada from the NJ area and brings with her an intensive U.S. tax experience. She has been in public practice for over 15 years and has specialized in both cross border transactions, structuring and re-structuring of U.S. operations, fund transactions and U.S. real estate transactions.
Susan Merlo joined the PricewaterhouseCoopers LLP in 1994 and obtained her CA designation in 1997. As part of PwC’s transfer pricing practice, she has advised a wide range of multinational companies in the preparation of transfer pricing documentation and audit defence that include companies in the consumer products, pharmaceuticals, oil and gas and automotive industries. Susan has also undertaken planning projects for clients in the banking, consumer products and telecommunications industries. Susan is also experienced in the documentation of intra-group service charges, having assisted clients in the banking and consumer retail industries with the preparation of this documentation.
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.
Jacob Molnar is a Manager in the International Tax Services group at Ernst & Young in Chicago, Illinois. As of June 2010, Jacob has over ten years of professional experience, 7 years with the Ernst & Young International Tax Services group. His ITS experience includes foreign tax credit utilization planning, international tax compliance (5471, 8858, 8865, 1118, etc.), earnings and profits and tax pool studies, and tax basis studies. Additionally, Jacob has experience in the use and set-up of various tax compliance software systems including: OneSource RS International, GoSystems RS, and CorpTax - International. Jacob previously worked with OneSource on the international help desk which assisted with preparation, implementation, and quantitative analysis concerning international calculations supported by the international software. Jacob has a Bachelor of Business Administration from Indiana University and is pursuing a Master of Taxation degree from the University of Illinois. He is an Enrolled Agent. Finally, Jacob has been an internal and external lecturer at international tax education seminars in the Chicago area.
Ivan Morales, a member of Baker & McKenzie's Tax Group, works primarily on international taxation. He previously served as tax counsel for Chevron Corporation and was clerk for the Honorable Judges Vasquez and Swift of the United States Tax Court in Washington DC. In addition to his practice, Mr. Morales is frequent speaker for the Tax Executive Issues and the Alliance for Tax, Legal and Accounting Seminars. He is a member of the State Bar of California Section of Taxation and the Florida Bar. Mr. Morales focuses his practice on transfer pricing planning and defense issues. He has represented taxpayers in the context of unilateral and bilateral APAs as well as in IRS examination and IRS Appeals Office settings. His extensive experience includes representing clients in the software, semiconductor, biotechnology and other technology-based industries in tax planning, transfer pricing and tax controversies.
Mark Mudrick is a Managing Director in the International Tax Services Group of the Philadelphia office of PricewaterhouseCoopers LLP. Mark has over 30 years experience in dealing with corporate and international tax issues involving multinational companies. His experience includes development and implementation of a broad range of tax strategies for United States multinational corporations investing abroad and foreign corporations investing into the United States. Mark has assisted multinational companies in establishment of international holding company structures, capital structure planning, including creation of tax efficient related party debt, and foreign tax credit planning including the use of techniques to maximum net foreign source income and reduce the impact of overall foreign losses. Mark has also had significant involvement in analysis and implementation of local country tax planning strategies. Prior to joining PricewaterhouseCoopers LLP, Mark was Staff Vice President, International Taxes at Unisys Corporation, and Manager, International Taxes at Hercules Incorporated. In addition, Mark was formerly Senior Tax Law Specialist in the National Office of the Internal Revenue Service in Washington, DC. Mark holds a Bachelor of Arts and a Juris Doctor Degree from Temple University and Masters of Laws in Taxation from Georgetown University. Mark often speaks before professional organizations on corporate and international tax matters. He was formerly an Adjunct Professor of the Masters level international tax course at Temple University School of Law.
Paul Mulvihill is a member of Ernst & Young’s Canadian Transfer Pricing practice and is based out of Ottawa, Canada. With more than 12 years of experience in transfer pricing, Paul focuses primarily on transfer pricing controversy, dispute resolution, and risk management. He is a member of Ernst & Young’s Global Transfer Pricing Controversy Network. Prior to joining the firm, Paul was the Advisor on Tax Dispute Resolution at the Organization for Economic Co-operation and Development’s (OECD) Center for Tax Policy and Administration in Paris, where he worked on various transfer pricing and tax treaty policy issues. Before moving to the OECD in April 2005, Paul was the manager of a Competent Authority Services Team in the International Tax Directorate of the Canada Revenue Agency. There he gained extensive experience in international tax controversy while managing advance pricing arrangements and mutual agreement procedure cases and developing policies on substantive transfer pricing issues. Paul spent the first five years of his Canadian public service career in various regional tax service offices and as an analyst with the Treasury Board Secretariat before moving to the International Tax Directorate in 1997.
Don Nemerov is a Managing Director, Compensation & Benefits Consulting Practice at Grant Thornton in Chicago. Don has over 25 years of experience designing executive compensation and pay-for-performance programs, and advising management and Boards of public and private companies. Don has worked with companies across virtually every industry, including technology, pharmaceuticals/biotech, media, financial services and banking, medical systems and devices, and distribution. These engagements include total compensation benchmarking, annual and long-term incentive plan design, equity incentives, phantom stock arrangements and non-qualified deferred compensation plans. He has completed numerous compensation projects for high growth, venture backed and pre-IPO companies. Don has also worked with numerous clients on regulatory matters, including ASC 718, Section 409A, and SEC proxy disclosure and CD&A drafting. Mr. Nemerov is affiliated with World @ Work and National Association of Stock Plan Professionals. Mr. Nemerov received his Bachelor of Science in Economics from Wharton School, University of Pennsylvania and his Masters degree in Industrial Relations from the University of Minnesota.
Trevor M. O’Brien is a chartered accountant based in the Toronto office of Ernst & Young where he is a key member of the international tax practice. Trevor has been in public practice for over 10 years and his experience includes advising clients on tax-effective structures for international business, cross-border mergers and acquisitions, technology transfers, financing, repatriation and tax minimization strategies. He has advised many public and privately-held companies located across eastern Canada and the U.S. on their international tax strategies and structures, and M&A transactions. Trevor has given presentations on international tax matters both in Canada and the U.S.
Ben Olivas is a partner in the International Tax group at DLA Piper in 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.
Greg Papinko is an associate partner at PricewaterhouseCoopers LLP in Toronto, ON. Greg specializes in U.S. international tax matters. He has serviced both U.S. based and non-U.S. based multinational companies during his 20 years of corporate and partnership tax consulting practice. He has assisted clients in developing and implementing worldwide tax planning strategies and oversees the tax reporting and compliance for various taxable and tax-exempt entities. Greg graduated from Arizona State University with a BA in 1984, an MBA in 1985 and a Masters of Taxation in 1990. He obtained his CPA designation in Arizona and Illinois in 1989 and his CA designation in Ontario in 1994. Greg has written various tax articles for Federated Press, Canadian Tax Highlights and Canadian Tax Journal and has presented at various seminars on US tax-related matters. He is also a member of the American Institute of Certified Public Accountants and the International Fiscal Association.
John M. Peterson, Jr. joined Baker & McKenzie in 1977 and has practiced in the area of corporate tax law, with a heavy emphasis on intercompany pricing, structuring of international operations and international tax planning generally, high technology tax issues, and federal income tax controversies. Prior to joining the San Francisco/Palo Alto office in 1981, Mr. Peterson practiced in the Firm’s Chicago office for three and one-half years. Mr. Peterson is currently the Chair of Baker & McKenzie’s Global Tax Practice Group. Mr. Peterson received his (Bachelor of Business Administration) at the University of Notre Dame and his J.D., cum laude, at Harvard University. American Bar Association, Section on Taxation, Affiliated and Related Corporations (1977); American Bar Association, Subcommittee Chairman; American Bar Association, Committee Vice-Chair; American Bar Association, Committee Chair (1991); State Bar of California, Committee Chair (1981). Mr. Peterson is a frequent speaker on intercompany pricing and international tax issues in general. He is also a past Chairman of the Committee on Affiliated and Related Corporations (which then had responsibility for section 482 issues and consolidated return issues); American Bar Association, Subcommittee Chairman (1980); American Bar Association, Committee Vice-Chair (1988); American Bar Association, Committee Chair; State Bar of California.
Melinda R. Phelan is a partner at Baker & McKenzie LLP in Houston and a member of the management committee for the Firm’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.
AJ Picchione is an International Tax Manager at KPMG LLP in Boston, MA. AJ joined KPMG in 2010 as a Manager in the International Corporate Services tax practice in New England. Prior to joining KPMG, AJ was a senior tax associate in the Boston office of an international law firm. AJ began his career as a tax associate in the New York office of an international law firm. AJ has over 5 years of experience providing domestic and international tax structuring advice and advising clients on the tax aspects of mergers and acquisitions. AJ specializes in international corporate taxation and has a strong background in corporate taxation, mergers and acquisitions, and taxation of affiliated and related groups. AJ’s experience includes assisting multinational corporations with global tax planning, restructuring projects, and foreign cash repatriation planning. AJ has worked with clients in a wide range of industries, including insurance, pharmaceutical, retail sales, media, technology and financial services. While at KPMG, some of the strategic clients AJ has worked with include Dunkin Brands and Keane International. AJ is a member of the International Fiscal Association (USA Branch) and the FAUST and USAFT Committees of the Tax Section of the American Bar Association. AJ received his BA at Boston College; his JD from Boston University School of Law and is a Member of the Bar in Massachusetts and New York.
Kenneth Picciano 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. Ken 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. Ken 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. Ken 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.
David M. Pincus is a partner is the leader of the international tax service practice in KPMG’s Houston office. David is a partner in the international practice of KPMG’s Houston office. He has twenty-six years of professional experience with KPMG, serving clients in several industries with a variety of needs. Specializations include oil field services, engineering, manufacturing and high technology companies, as well as those involved in inbound and/or outbound investment. David received a BBA in Accounting from the University of Massachusetts at Amherst and an MPA from the University of Texas at Austin. David is a Certified Public Accountant and a member of the AICPA; TSCPA.
Doug Poms is a partner with KPMG’s Washington National Tax’s International Corporate Services Group where he specializes in international tax planning. Doug has many years of experience advising multinational clients with respect to cross-border acquisitions, financings and restructurings involving subpart F income, foreign tax credit, tax treaty, FIRPTA, withholding and corporate inversion issues. Doug has spoken on numerous occasions at conferences in the United States, Canada and Europe regarding various U.S. international tax topics. Prior to joining KPMG in 2002, Doug was an associate with Dewey Ballantine LLP in Washington D.C. and London. Doug also served as a judicial law clerk at the Court of Federal Claims. Doug’s education, licenses, and certifications include JD, University of Virginia (order of the coif); MBA, in international finance, George Washington University; BS, in accounting, University of Virginia; and a Member of the Virginia State Bar and the District of Columbia Bar.
Pat Powers is a partner at Baker & McKenzie in Palo Alto, CA. Mr. Powers is a recognized innovator in corporate tax matters and a pioneer in developing many of the techniques used by multinationals to reduce their global tax burdens — including factoring companies and using foreign entities classifiable as partnerships for US tax purposes. Mr. Powers also played a key role in the development of the check-the-box regulations. He is a member of the American Bar Association Section of Taxation and Committee on State and Local Taxes and the State Bar of California. Mr. Powers focuses his practice on state and local tax matters, global tax minimization, general tax planning, and tax controversy and litigation. In recent years, Mr. Powers has also devoted significant effort to effective state tax planning for businesses, as well as representing taxpayers in state administrative appeals and in court. Representative legal matters: Provided global tax planning for a wide range of clients from midsize public and private companies up to Fortune 100 companies in industries ranging from high-tech, biotech and pharmaceuticals to financial services and transportation; Successfully represented a wide variety of cases at the audit, appeals, and administrative level; Drafted and successfully urged legislative solutions for state tax problems not amenable to adequate judicial resolution. Pat received his J.D. (Order of the Ciof) from University of California at Berkeley and his B.A. from the University of California at Berkeley.
Salim Rahim is a partner at Baker & McKenzie in Washington, DC and has extensive experience in transfer pricing matters, including transfer pricing planning, compliance, and tax controversy. He has represented clients in all administrative phases of a controversy through litigation in the US Tax Court. He has also represented companies in various alternative dispute resolution forums, particularly the Advance Pricing Agreement Program. Mr. Rahim is a frequent speaker on transfer pricing matters in seminars sponsored by various organizations and universities. Mr. Rahim advises clients on matters involving examination, appeals, advance pricing agreements, and Competent Authority. In particular, his practice involves negotiating and consummating Advance Pricing Agreements for US- and foreign-based multinational companies in the software, e-commerce, pharmaceutical, manufacturing, automobiles, sports footwear and apparel, financial services and other industries. Mr. Rahim also advises companies on global transfer pricing documentation requirements. Represented First Data Corporation and Subsidiaries v. Commissioner, U.S. Tax Court Docket No. 7042-09 (various transfer pricing issues and other international tax issues under sections 482 and 367(d).
Brian Reed is a senior manager in Ernst & Young LLP’s National Tax Mergers and Acquisitions group, Transaction Advisory Services practice, based in Washington, D.C. He focuses on advising clients on internal restructuring transactions, corporate acquisitions, dispositions, spin-offs, reorganizations, spin-offs, consolidated return issues, and cross-border transactions. Brian obtained his Masters of Science in Accountancy and his Bachelors of Science in Finance from the University of Akron.
Ronald Saake is an international tax partner with Deloitte in San Francisco and San Jose. He is also the partner in charge of Deloitte’s transfer pricing practice in the Bay Area and the Pacific Northwest. Ron has been a tax practitioner since 1986 and became a partner with another international accounting firm in 1996. He has worked in the international tax area his entire career. Ron works with both public and private companies in structuring new international operations and in optimizing ongoing operations. He has significant experience in mergers and acquisitions, planning involving intangible assets, and structuring to help companies minimize their worldwide effective tax rate. Ron has deep expertise in tax accounting matters (ASC 740). For the last several years, Ron has been recognized by the International Tax Review as a leading tax advisor, and in 2007, 2008, 2009, and 2010 was recognized by Euromoney and the Legal Media Group as one of the world’s leading tax advisors. Ron graduated from the University of California at Berkeley with an MBA in 1985 and from the University of California at Riverside with a BS in Administrative Studies in 1982. He is a California CPA.
Jeffrey L. Sanders is a Partner at Weaver LLP with 27 years experience of tax planning and tax compliance experience. Jeff has significant industry experience in areas of manufacturing, wholesale/distribution and retail businesses, as well as, significant experience with multi-state tax planning and compliance issues. Jeff received his Master of Accounting in Taxation from Texas Tech University and his Bachelor of Business Administration in Accounting from Texas Tech University. He is the Vice President of the CPA Manufacturing Services Association, a member of the Texas Society of Certified Public Accountants, a member of American Institute of Certified Public Accountants, a member of Texas Tech University Accounting Advisory Board and is the author of tax articles in AICPA publication and The Tax Advisor.
Gary Scanlon is a manager in Ernst & Young’s International M&A Tax group in Chicago. He concentrates his practice in the area of Subchapter C, with a particular focus on repatriation planning and cross-border M&A transactions. Before moving to Chicago, Gary was a member of Ernst & Young’s National M&A Tax group based in Washington, D.C. Gary has authored or co-authored several publications, including a New York State Bar Association report on “overlap” transactions, a University of Chicago report on the movement of attributes in taxfree reorganizations, and a reoccurring column on various cross-border M&A issues entitled “RuM&Ations.” He has appeared on numerous cross-border M&A panels. In 2006, Gary “thru-hiked” the entire 2174.6 miles of the Appalachian Trail, from Georgia to Maine. During the 5 and a half month sojourn, Gary had the good fortune of meeting his future wife, a fellow thru-hiker. He currently participates in Junior Achievement, an organization dedicated to educating students about workforce readiness, entrepreneurship and financial literacy through experiential, hands-on programs. Gary received a BA in Classics from Ohio University, a JD from the University of Chicago Law School, and an LLM in Taxation from the Northwestern University School of Law.
Ken Schuckers is a Tax Specialist and Services, Section 199 - Domestic Production Activities Deduction, and Tax Accounting Methods. Ken’s primary focus is on Federal and state Research & Development (R&D) tax credits and incentives, tax accounting methods and periods, cost classification and fixed assets, and the Domestic Production Activities Deduction. He has over twenty years of corporate tax experience and has spent the last thirteen years primarily focused on federal tax credits and incentives. He has extensive experience in implementing and managing an array of tax consulting projects for the advanced manufacturing, aerospace and defense, commercial construction, food processing, engineering services, financial services, life sciences, and software industries. Ken has significant experience representing clients before the Internal Revenue Service during audits at the field and appeals levels, including working with the MITRE group. Ken also has a broad corporate tax background. Prior to joining the C-SFTS tax services group Ken spent seven years in corporate tax consulting and compliance. Ken received his Bachelor’s of Business Administration Degree from Clarion University of Pennsylvania. He has a CPA in Georgia and Pennsylvania.
Eric B. Sensenbrenner is a Partner at Skadden, Arps, Slate, Meagher & Flom LLP in Washington, DC. Eric Sensenbrenner represents clients on a broad range of domestic and international tax matters. With a particular emphasis on transactional tax planning in the international context, Mr. Sensenbrenner has extensive experience in assisting clients in the planning and execution of mergers, acquisitions and spin-off transactions. He regularly advises clients in connection with cross-border merger and acquisition transactions, and post-acquisition restructuring and integration transactions and represents clients in connection with the formation of domestic and foreign joint ventures. Mr. Sensenbrenner also regularly advises clients on international tax planning matters generally, including subpart F, the foreign tax credit and transfer pricing. Mr. Sensenbrenner is a frequent author and lecturer on topics related to international taxation.
Margaret A.R. Shulman is a Senior Manager in Ernst & Young LLP’s International 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.
David Sotos is a partner at PricewaterhouseCoopers LLP in San Jose, CA. Mr. Sotos focuses his practice on international tax matters, including mergers, acquisitions, foreign tax credit and other planning with respect to U.S.-controlled foreign corporations. Mr. Sotos joined the firm in 2007 after serving more than 10 years in various capacities for the government. Mr. Sotos has considerable knowledge with respect to the withholding tax provisions, the dual consolidated loss provisions and the provisions relating to cross-border asset and stock transactions. While at the IRS Office of Chief Counsel and the Department of Treasury, Mr. Sotos authored the regulations under Section 1446 relating to partnership withholding and was extensively involved in the modernization of the dual consolidated loss regulation. While at the Treasury, in addition to working on regulations and other guidance, Mr. Sotos was intimately involved in the negotiation and completion of several U.S. tax treaties. Mr. Soto received his B.S.B.A., Ohio State University, 1991 (cum laude), J.D., Capital University School of Law, 1994 (summa cum laude), and a LL.M. at the University of Florida School of Law, 1995.
Sloan G. Speck is an associate in the Chicago office of Skadden, Arps, Slate, Meagher & Flom LLP. Sloan has experience in a broad range of federal income tax matters, including mergers and acquisitions, joint ventures, real estate transactions and real estate investment trusts, bankruptcy restructurings and other workouts, and various types of financings. Sloan received an L.L.M. in taxation from New York University, a J.D. (with honors) and M.A. (history) from the University of Chicago, and a B.A. from Rice University.
Jennifer Sponzilli is an International Corporate Services Tax Principal at KPMG in London. Jennifer specializes in tax structuring of cross-border structured financings, tax-free reorganizations, and taxable acquisitions, focusing on tax treaties, withholding tax, foreign tax credits, and anti-deferral regimes. Jennifer has experience in advising both U.S. and non-U.S. based financial institutions on the tax aspects of cross-border transactions. Jennifer also has extensive experience in managing large scale tax compliance engagements for the same client base. Jennifer joined KPMG’s Federal Tax practice in 1997 upon graduation from law school, where she worked primarily with U.S. branches of Japanese banks. In 1999, Jennifer transferred to the International Corporate Services practice, where she continued to focus on financial institutions and cross-border structured financings. Jennifer received her B.A. in economics with concentrations in accounting and finance from Rutgers University, J.D. degree from Chicago-Kent College of Law, and LLM –Tax from New York University. Jennifer is a member of the International Fiscal Association and New York State Bar Association.
David Steinberg is a partner at Heenan Blaikie in Toronto, Ontario, Canada. David is a business lawyer specializing in the areas of entertainment, media and intellectual property. David primarily practices in the film, television, music, and book publishing industries. He acts for film and television producers and distributors, broadcasters, Internet service providers, publishers, creators and manufacturers of home entertainment products and merchandise. David advises his clients in both Canada and the United States on matters related to film and television financing, production and distribution, the licensing of intellectual property for integrated media products and the sale and acquisition of rights. David is a dynamic advisor who consistently applies a pragmatic approach to his practice. As a result, he has developed strong, long-lasting relationships with his clients. David is highly service-oriented and committed to assisting his clients in achieving their goals. He combines superior legal skills, industry experience and an adaptable approach to communicating and negotiating in all types of business transactions. David joined Heenan Blaikie in 1993 after working at another major law firm in Toronto. He became a partner in 1998. Prior to becoming a lawyer, David was a professional musician and recording artist, who toured extensively throughout the United States and Canada as a drummer in various rock bands. David is a frequent speaker and lecturer on various media and entertainment law related topics in both Canada and the United States. He is peer-rated as “most frequently recommended” in the annual Canadian Legal Lexpert® Directory and is recognized as one of Canada’s leading lawyers in the area of entertainment law in the 2011 edition of The Best Lawyers in Canada (Woodward/White). David is also listed as one of the top 500 leading lawyers in Canada in entertainment law in the Lexpert®/American Lawyer Guide to the Leading 500 Lawyers in Canada.
Paul Tadros exemplifies the international nature of our firm having lived and worked in different countries throughout his life. He holds a MSc in Applied Mathematics and Physics, as well as an LLM in tax. In addition, he is a CPA and a Chartered Accountant (Canada). Paul provides close to three decades of both industry and large public accounting experience. During his roughly 20 years working in industry, Paul managed the international tax functions of two US-based multinational companies with operations in the Americas, Europe and Asia. In addition, as a partner in the Big 4, Paul also worked in Montreal and the Caribbean as a specialist in US practical inbound and outbound tax planning. He has also spent time during his career based out of New York. Paul maintains a profound depth of knowledge in US inbound and outbound planning. He has extensive experience in cross border mergers and acquisitions, reorganizations, corporate structuring, financing and initial public offerings. He is respected around the world for his extensive knowledge of income tax treaties, and he has consulted with foreign governments on treaty policy and legislation affecting international tax and business issues. Paul is a frequent speaker at international tax conferences and has authored numerous articles on international tax. A particular specialty of his is the tax systems of Latin America and the Caribbean. He also founded and became the first President of The American Chamber of Commerce in the Eastern Caribbean.
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.
Michael Teper is a Senior Manager in the U.S. tax consulting practice of Ernst & Young in Toronto. With over 11 years of experience in U.S. tax consulting, Michael serves a variety of Canadian and U.S. based multinational clients, and leads engagement teams on projects that include the design and implementation of international financing structures, funds repatriation, tax attribute studies, mergers and acquisitions, and restructurings. Michael is a graduate of the J.D/M.B.A. program at the University of Toronto, and is admitted to the bars of Ontario and New York.
Mary K. Thomas is a Partner-in-Charge, International Tax Services, at Weaver & Tidwell LLP in Houston. Mary has 28 years of combined tax and accounting experience that includes more than 15 years of international tax and IRS examination experience. Her practice emphases on global restructuring and refinancing strategies; cross-border transactional planning and management; transfer pricing compliance, documentation and planning; strategic re-sourcing of income and expenses; global VAT, custom duties and tariff compliance/planning; and IRS audit controversy services. She has private sector experience with a medical device manufacturer/distributor as manager of transfer prices and director of international tax, as well as, Advance Pricing Agreement (APA) Program experience by negotiating both unilateral and bilateral APA transfer pricing agreements. She has three years experience working for Big 4 advising on Transfer Pricing matters. Ms. Thomas received her Juris Prudence Doctorate from Washington College of Law at American University in Washington DC; her Master of Taxation from University of Texas at San Antonio and her Bachelor of Business Administration, Accounting from University of Texas at San Antonio.
Brian Trauman is a Tax Principal in KPMG’s Economic and Valuation Service practice, and is the U.S. East region leader for transfer pricing controversy services. Brian helps clients manage and resolve disputes and respond to the challenges that come with transfer pricing controversies, whether related to intercompany pricing between the U.S. and other countries or between U.S. states. Prior to joining KPMG, Brian was a partner with a multinational law firm, where he was responsible for assisting multinationals with a wide range of both U.S. and non-U.S. tax controversy and transfer pricing matters, including transfer pricing structures and supply chains, advance pricing agreements, mutual agreement procedures, documentation, intercompany agreements, and audits, appeals, and litigation. His clients include leading companies in such industries as the automotive, agricultural, chemical, finance, oil and gas, technology, and telecommunications sectors. Brian has responded to state, federal and foreign information document requests, liaised with exam teams, drafted protests to notices of proposed adjustments, presented cases to appeals teams, and participated on litigation teams. In addition, he has interacted with Congress, the IRS, Treasury, and the OECD for changes to Income Tax Code, Regulations, and other guidance. Brian also has served as an attorney-advisor with the U.S. Tax Court. Brian is a frequent speaker and writer on a wide range of transfer pricing and controversy topics, including the IRS’s Schedule for Uncertain Tax Positions, business restructurings, implementing the US services regulations, valuation of intangibles, choice of administrative and judicial forum, and advance rulings. These engagements include presentations and publications for ABA, BNA, OFII, IBFD, the United States Tax Court and other events. Brian has also guest lectured on transfer pricing topics for NYU’s LL.M. program, and for the Republic of Colombia’s international tax examiners.
Theodor van Stephoudt is an economist with SNR Denton in New York. He has extensive experience working with clients in providing assistance in the development of transfer pricing documentation, the planning of appropriate intercompany prices and the valuation of intangibles, tangible assets and entities for tax purposes. He has defended clients in tax audits conducted by the US Internal Revenue Service (IRS) and tax authorities in Europe and in Asia. His clients are multinational companies with cross-border intra-group transactions. He has advised clients of all sizes, from smaller start-up companies to very large, well-known global multinational corporations. He has analyzed intercompany pricing and fee structures for various industry sectors including manufacturing, high-tech and financial services, and provided analyses regarding royalty rates including brand name royalties and related tax and transfer pricing advice. Mr. van Stephoudt has developed management fee systems for clients in a number of industries and has assisted clients in determining the most advantageous location for intangibles/value drivers. During his five years in Switzerland, he assisted clients with the establishment of principal structures in Switzerland. Mr. van Stephoudt has also advised clients in obtaining advance pricing agreements on a bilateral and unilateral basis. Unilateral advance pricing agreements were established with the IRS. Mr. van Stephoudt advised on bilateral advance pricing agreements with Switzerland, Germany and Denmark. Mr. van Stephoudt has valued trademarks, technologies, start-up companies, other tangible and intangible assets and entire corporations. He has assisted in due diligence processes to evaluate potential transfer pricing risks.
Alex Waniek is a member of Ernst & Young LLP’s International Tax Services practice and is based in Irvine. Alex’s primary role is to assist multinational clients establish and coordinate their international activities in the most tax-efficient and administratively feasible manner. With over 18 years of experience in public accounting, Alex has extensive practical experience in developing and implementing foreign structures, tax-efficient supply chain structures, global investment and financing arrangements and repatriation strategies. He has managed significant projects for clients operating in the high technology and engineering and construction industries. Alex received a B.A. in economics from UCLA, and a J.D. and an LL.M. in taxation from the University of San Diego School of Law.
Steve Weerts, an associate in the Tax practice, 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. Steve received his LL.M., Taxation, Loyola Law School Los Angeles; his J.D. from Loyola Law School Los Angeles and his B.S., Accounting, Loyola Marymount University.
Jim Wilson is a partner in Gowlings' Ottawa office, practising in conjunction with the Firm's National Tax Practice Group. His practice focuses on helping organizations optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. Jim’s tax experience involves the administration of domestic corporate and international tax with the Canada Revenue Agency (CRA) for 32 years. Jim held various positions with CRA's Income Tax Rulings Directorate ("Rulings"), the Canadian Competent Authority Division ("Competent Authority"), the Training and Learning Directorate and the Legislative Policy Division. During Jim's tenure as both a senior officer and a senior manager of the International Section in Rulings, he participated in hundreds of Advanced Income Tax Rulings and Technical Interpretations on a wide range of international technical issues. As a senior manager with Competent Authority for six years, Jim has been successful in resolving a number of controversial international double tax cases through successful negotiations with tax authorities in a number of countries around the world. Even though Jim developed an impressive specialty with tax treaties during his last 10 years with the CRA, he possesses a vast array of experience with issues such as residence and dual resident cases, permanent establishments, benefit conferrals, tower structures, e-commerce income characterization, hybrid entities, foreign entity classifications, foreign tax credit system, and Canada's withholding tax system. From his tenure as a senior manager with Competent Authority Services, Jim's experience expanded to a multitude of technical and policy issues pertaining to the CRA's MAP and APA programs. This would include expertise on ACAPs, interest relief, secondary adjustments, notional expenses, imputed interest, Article XIII(8) agreements, and S-Corp agreements. Jim acquired his CGA designation in 1987. For a period of approximately 10 years he was also the CGA Ontario instructor, in the Ottawa Region, for its Advanced Tax Program.
Kent Wisner is based at Taxand USA where he is Managing Director with Alvarez and Marsal Taxand US, in San Francisco. He specialises in international tax planning for multinational enterprises with multi-jurisdictional operations, as well as cross-border transactions and tax controversies involving international issues. With more than 25 years of international tax and M&A experience, Mr Wisner has extensive experience in advising companies in the consumer business, computer hardware, software, semiconductor, e-business, private equity and transportation industries and has spent more than two decades focusing on international tax issues in the areas of operations planning, transaction structuring, intercompany pricing analysis, and advocacy in federal tax controversies at the audit and appellate levels. Mr Wisner has also advised sovereign wealth funds on the tax aspects of their international investments. Prior to joining Alvarez and Marsal Taxand, Mr Wisner spent 10 years with Baker & McKenzie, where he was an International Partner and served on their North American Tax Practice Group Management Committee and another 10 years as a Principal providing international tax services in the Big Four environment. Most recently Mr Wisner led the Silicon Valley tax practice of K&L Gates LLP, a global law firm with 37 offices on three continents. Mr. Wisner earned a bachelor’s degree in International Relations and Russian from Stanford University in 1980, a master’s degree from the Fletcher School of Law and Diplomacy at Tufts University in 1983, and a juris doctor degree from the University of Virginia School of Law in 1986, where he was a member of the Articles Review Board of the VA.L.REV.
John Woodruff is a partner in the law firm of McDermott Will & Emery LLP and 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 in Ernst & Young LLP’s International Tax Services Transfer Pricing practice. Steve is located in Washington, D.C. He brings over nearly 30 years of tax experience, including nearly 20 years of extensive experience in all aspects of transfer pricing across all industries. Steve’s knowledge in transfer pricing controversy includes examination, appeals, alternative dispute resolutions, advance pricing agreements, mutual agreement procedures and customs agreements. His combined advance pricing agreements and mutual agreement procedures experience is in excess of 100 cases. Previously, Steve was a partner at a global law firm. Prior to that, he spent 10 years as a partner and director of the advance pricing agreement practice at another Big Four firm. Steve also brings a wealth of government experience to Ernst & Young, having served as an attorney at the Internal Revenue Service Office of Associate Chief Counsel (International) Advance Pricing Agreement Program. Steve is actively involved in the international tax and transfer pricing community. He 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 is an Adjunct Professor (Transfer Pricing) at Georgetown University Law Center and New York University School of Law. He has published a leading transfer pricing treatise and over 100 articles on transfer pricing topics. Steve speaks globally on transfer pricing and dispute resolution.
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.