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    Networking Seminars Inc.

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    Faculty Biographies

    Please also see each seminar page for additional biographies

    John Apuzzois an International Tax Senior Manager located in the Costa Mesa / Los Angeles office of Deloitte Tax LLP, serving clients in the Western Region. He has over 16 years of international taxation experience. John has been part of an International Tax services group of another Big 4 accounting firm having worked for their Montreal, Toronto, Vancouver, Edmonton, Halifax, Miami, Seattle, New York, Los Angeles, Hawaii, Denver, Phoenix, and Irvine, California offices. John has headed an international high wealth practice and has been involved in personal tax minimization having extensive experience with the individual tax aspects of international executive transfers and wealth transfer planning. More recently, John has been involved in sophisticated U.S. corporate tax planning assisting U.S. based and foreign based multi-nationals with cross-border transactions including corporate restructuring, acquisitions and divestitures. John has had both inbound and outbound experience for public and private multi-nationals. He has assisted various multi-nationals with developing and implementing efficient global tax structures while not compromising their business operations. He has assisted various multi-nationals in meeting their U.S. international tax reporting obligations as well as assisted in the audit, preparation and review of ASC 740 – Accounting for Income Taxes. John has served clients in the following various industries such as Hospitality, Hi-Tech, Manufacturing, Education, Transportation, Real Estate, Insurance, Pharmaceutical, Healthcare, Construction & Engineering, and Energy.  Mr. Apuzzo is a member of the American Institute of Certified Public Accountants, California CPA State Society, Illinois CPA State Society, newly created Canadian Chartered Professional Accountant (unification of the Canadian Institute of Chartered Accountants and the Society of Certified Managements Accountants of Canada), and the Canadian Institute of Chartered Business Valuators. He is also a member of the Canadian Tax Foundation and Society of Trusts and Estate Practitioners.

    Sherif Assef joined Duff & Phelpsin 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.

    Jason R. Conneryis a principal at KPMG LLP in the International Tax group of the Washington National Tax practice. He provides tax advice to foreign-based multinational companies, including insurance companies, and private equity funds on a wide range of matters, including branch taxation, FIRTPA, sourcing of income, allocation and apportionment of expenses, foreign currency taxation, and income tax treaty issues. He also provides tax advice to U.S.-based multinational companies on matters involving offshore earnings deferral, foreign tax credits, subpart F, and foreign currency and interest rate risk management in offshore treasury centers.  Jason has worked extensively in the area of cross-border finance and financial products.  He is a frequent speaker and writer on U.S. international tax issues.  Jason rejoined KPMG LLP in 2006.  Prior to that, he was a director of the Structured Finance Group at an investment bank in New York City, where he developed and implemented cross-border financings for the investment bank. Previous to working at the investment bank, Jason was a senior manager in the International Corporate Services group of KPMG’s Washington National Tax practice. Before that, Jason was a member of KPMG’s Financial Services practice in New York City, working primarily with foreign-based financial services institutions engaged in business in the United States. Jason earned his LL.M. from New York University, his JD, cum laude from The John Marshall Law School, and his BS in accounting, with honors, from University of Florida.

    Paul Dau is counsel in the law firm of McDermott Will & Emery LLPbased 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.  

    Tim Fitzgibbon is a Director in the International Tax Services group of PricewaterhouseCoopers in San Jose.  Prior to joining PwC, Tim was a Senior Associate at Fenwick & West, one of the top law firm tax practices on the West Coast.  His practice focuses on international tax planning for both the outbound operations of U.S. multinationals and the inbound operations of foreign multinationals.  This includes advice on domestic and international tax planning, structuring mergers and acquisitions, internal restructurings and operations, and joint ventures.  Tim has co-authored and authored articles on U.S. international tax rules and developments. He has lectured to professional and industry groups on various topics including the provisions of Subpart F, foreign currency, dual consolidated losses, the foreign tax credit, and international partnerships and joint ventures.  Tim attended law school at Loyola Law School, graduating with a J.D., cum laude, Order of the Coif, in 1998 and received an LL.M in Taxation from New York University School of Law in 2001.

    Steven M. Davis is a Principal in the International Tax Services group at Deloitte Tax, LLP’sNew York City office with over 22 years of international tax experience.  Steven is the East Regional Leader of Deloitte’s Business Model Optimization (BMO) practice and is a member of the global BMO leadership team.  The BMO practice focuses on helping multinational companies across all industries integrate their operational and tax planning in a scalable and sustainable way to help business leaders make more effective decisions on an after-tax basis.  Steven has extensive experience assisting US and non-US multinational organizations in identifying and implementing strategies for minimizing global taxation.  These strategies encompass matters related to the migration of intangibles, supply/value chain planning and other business transformation strategies.  In this regard, he has significant practical experience in the assessment, design, implementation and post-implementation maintenance of global strategies to achieve sustainable tax-aligned operational synergies for some of the firm’s key clients.  An integral part of his experience includes project management and effective resolution of critical business, tax and legal issues, through careful and pro-active coordination between the client’s financial and operational stakeholders driving such business transformation strategies.  Prior to joining Deloitte, Steven was the International Tax Director at Loral Space & Communications Ltd.  Prior to that, Steven practiced tax law in the New York City office of the law firm of Akin, Gump, Strauss, Hauer & Feld, LLP.  Steven obtained his LL.M. (Taxation) from NYU School of Law, his JD from Hofstra Law School and his BS (Accounting) from Syracuse University.  Steven also is a frequent lecturer on topics related to IP and supply chain planning.

    Rui Fan is a Managing Director at KPMG LLPin New York.  Rui has 11 years of experience in advising multinational companies on transfer pricing, valuations, business restructuring, intellectual property planning, and other tax and financial related issues in the United States and Asia-Pacific region.  Rui also spent over one year in Singapore in developing the transfer pricing teams in Asia Pacific. Rui has performed transfer pricing planning and documentation engagements related to tangible property, intangible property, and services with a focus on intangible-related issues, such as licensing arrangements, cost sharing arrangements and intangible sales for clients in the pharmaceutical industry.  Her clients cover a broad range of industries, including fast-moving consumer goods, consumer electronics, industrial markets, agricultural products, the retail industry, software, and financial services industries.  In addition, Rui provided valuation services for both U.S. and international, public and private businesses for the purposes of mergers and acquisitions, corporate restructuring, property tax, employee stock ownership plans, divestitures, financial (ASC 350 and 805), and tax reporting.  In connection with these assignments, she valued the following securities and assets: publicly-traded and closely held common stock (on both a controlling and minority level), preferred stock, stock options and warrants, debt instruments, software, warranties, customer relationship, trade names, patents, non-compete agreements, licenses, software, copyrights, trained workforce, and contracts. Rui received her M.S. in Management Information Systems from Carnegie Mellon University and her B.S. from International Finance at Renmin University of China.

    Paul Flignor is a Principal Economist with DLA Piper'sTax group based in Chicago.  He concentrates his practice in intercompany pricing and intellectual property valuation.  He has more than 17 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing and financial economics. He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies.  Mr. Flignor has worked extensively in the automotive, information services, software, consumer products and electronics industries. Over the years, he has successfully run transfer pricing and valuation projects for a variety of purposes, including:  Intercompany pricing, including audit defense, Advanced Pricing Agreements, cost sharing and intangible migration, and global documentation; Business valuation for both tax and financial reporting purposes, including purchase price allocation; Transaction support, including due diligence analysis and pre- and post merger integration planning; Intellectual property valuation and management.

    Alexander Hanhan is a Tax Managing Director with the International Corporate Services group in KPMG’sHouston office.  Alexander works with many multinational clients, primarily oil field services and manufacturing industries, on international tax-related projects. He consults on cross-border reorganizations, acquisitions, dispositions and other debt-financed transactions.  Alexander provides tax advice on efficient business structures for U.S. based businesses expanding into global markets and foreign-based businesses expanding into the U.S. He assists with the international aspects of U.S. tax and financial reporting, earnings and profits calculations, foreign tax credit calculations, U.S. GAAP and IFRS, and other compliance projects.  Alexander speaks on international tax matters for organizations such as the Tax Executives Institute, the Council for International Tax Education and Networking Seminars.  Alexander earned his Masters of Laws in Taxation from New York University; his JD from Brooklyn Law School and his BA in Business Economics from University of Texas.

    Justin Hill is an associate with Baker & McKenziein New York.  His practice focuses on a wide range of federal income tax matters, including domestic and international tax issues related to mergers, acquisitions, and dispositions as well as equity and debt offerings.  Justin began his career as a certified public accountant with KPMG LLP's state and local tax practice in 2004 and subsequently worked in the state and local tax practice at another international law firm before joining Baker & McKenzie in 2012.  He received his J.D. magna cum laude from Fordham University School of Law and his B.B.A. from Baylor University. 

     

    Mark Horowitz is an associate in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Houston office. Mark represents multinational enterprises in international transfer pricing and tax controversy matters.  He advises clients with respect to Advance Pricing Agreements, Competent Authority cases, the planning, structuring and documenting of controlled group transfer pricing arrangements, and the accounting and reporting of uncertain tax positions.  He has significant experience in U.S.-Japan, U.S.-United Kingdom, and U.S.-Canada Competent Authority cases and Advance Pricing Agreements.  Mark’s clients include companies from the consumer products, software, engineering and construction, chemical, and oil field services industries, among others.  Mark regularly represents clients in tax controversies before the Internal Revenue Service and state and local tax authorities, and handles litigation in transfer pricing and other contexts.  In addition to his tax controversy work, he advises clients on a broad range of state and federal tax issues. Mark has been named a “Texas Rising Star” by Law & Politics Media Inc., as published in Texas Monthly Magazine.  He has spoken on tax-related topics, including transfer pricing, Competent Authority proceedings and Advance Pricing Agreements, at numerous tax conferences. Mark is admitted to practice in Texas and before the U.S. Court of Federal Claims and the U.S. Tax Court. He earned his J.D. from University of Virginia School of Law and his B.A. from Harvard University. 

    Kathrine Kimball is a principal of Deloitte Tax LLP in the San Diego office. Ms. Kimball’s extensive experience includes both international and domestic transfer pricing, encompassing documentation, planning, and controversy defense as well as supply-chain based tax planning. Ms. Kimball has served major multinational clients in a wide range of industries, including: apparel, automotive, bio-tech, chemicals, construction, consumer products, electronics, financial services, food and beverages, including beer, wine, and spirits, gaming, pharmaceuticals, professional services, real estate, retail, and technology. Having specialized in transfer pricing for over 20 years, she has managed a multitude of global, pan-European, pan-Asian, and North American international supply chain transformation or post-merger integration projects, as well as the US domestic aspects of such projects, involving the restructuring and optimization of the tax structure within the context of a business reorganization. Kathrine has been named again among the "World's Leading Transfer Pricing Advisers" in the 2013 Expert Guide published by Euromoney's Legal Media Group.  She has also been named by in-house counsel in both the first and second edition of Euromoney's "Guide to the World’s Leading Women in Business Law" in 2012 and 2013.

    Neal Kochman is a member ofChaplin & Drysdalein Washington, DC.  Mr. Kochman's practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters. His experience covers a broad range of international, domestic, and state tax issues associated with transfer pricing, foreign tax credit planning, corporate restructurings, qualified settlement funds, and withholding and reporting. Mr. Kochman regularly advises clients on tax controversy matters, providing assistance during tax audits and representation in IRS Appeals proceedings, as well as in technical advice and ruling requests to the IRS National Office. He has represented U.S. multinational companies and U.S. subsidiaries of Belgian, German, Swedish and other foreign parents in advance pricing agreement and competent authority negotiations. Prior to joining Caplin & Drysdale, Mr. Kochman spent over 20 years performing quantitative and policy analyses for federal government agencies, which included: conducting econometric and statistical studies and developed cost allocation and pricing models, developing renewable energy research and development plans, and conducting defense acquisition policy studies. Mr. Kochman has written, been a guest lecturer at Georgetown University Law Center, and spoken at professional meetings on a variety of international and general tax topics, including foreign tax credits, transfer pricing, and the research credit. Mr. Kochman received his J.D. from Georgetown University Law Center, cum laude; Georgetown Law Journal; his M.I.E. from Cornell University and his B.S. from Cornell University.

    Nelly Korsun joined Duff & Phelpsas a director in the New York office. Nelly has over ten years of experience providing economic and business consulting services in the areas of transfer pricing and valuation. Throughout her career Nelly has advised clients on complex transfer pricing issues for global tax planning, documentation and supply chain restructuring initiatives. She has provided litigation and audit defense support in controversy matters, advised on intangible property valuation issues and cost-sharing arrangements, and performed transfer pricing reviews within M&A due diligence processes. Nelly also has considerable experience advising clients’ senior management teams on issues surrounding intercompany financing, including debt capacity, interest rates, risk transfers, guarantees and cash pooling arrangements. Nelly assists clients across a number of industries, most notably life sciences and medical devices, and financial services. Her client base also includes companies within specialty chemicals, automotive, consumer and industrial products, and telecommunications. Prior to joining Duff & Phelps, Nelly was a director at Ceteris, an independent transfer pricing and valuation firm. She also spent several years with BDO Seidman LLP and Charles River Associates. Nelly received her M.B.A., with honors, from the Johnson School at Cornell University, and a B.A. from Barnard College at Columbia University. She also holds a professional certificate in Credit Analysis and Credit Risk from the New York Institute of Finance and is progressing towards a certification in Business Valuation from American Society of Appraisers (ASA).

    Jason LaRosa is a Director at KPMG LLPin Houston.  Jason works with many multinational clients, primarily in the oil field services, offshore drilling and manufacturing industries, on international tax-related projects.  He consults on cross-border reorganizations, acquisitions, dispositions and debt-financing, specializing in structuring transactions to minimize worldwide taxes.  Jason provides tax advice on tax efficient business structures for U.S. based businesses expanding into global markets and foreign-based businesses expanding into the U.S.  He assists with the international aspects of U.S. tax and financial reporting, earnings and profits calculations, foreign tax credit calculations, U.S. GAAP and IFRS, and other compliance projects.  Jason is a CPA and earned his Master of Laws in Taxation from the University of Missouri and his JD from Duquesne Law School and his BS in Accounting from St. Vincent College.

    Jeffrey A. Levenstam is an international tax services partner at Ernst & Young LLPbased in San Francisco.  He joined the Ernst & Young’s International Tax Services Group in 2005. Jeff has practiced international tax for over 33 years as a tax professional and corporate tax executive. Before joining EY, Jeff served as the Senior Director of International Tax, M&A and Customs at Cisco Systems, Inc. from 2000 to 2005.  Prior to that, Jeff was a partner at another Big Four Firm.  Jeff has extensive experience advising U.S. and foreign based multinational businesses in all aspects of international taxation, including transfer pricing, subpart F and dividend planning, capital structuring and foreign operational issues.  Jeff also has extensive experience in structuring and operating IP ownership and tax efficient supply chain structures.  Jeff also has a concentration of clients in the internet and software industries with their own set of supply chain/service issues related to server locations, PE challenges, revenue characterization issues, etc.  Jeff has the experience of being the in-house executive responsible for Cisco Systems international tax and customs planning, compliance and tax audit defense work. He was also responsible for all tax aspects of acquisition planning and integration, strategic investments and alliances, and joint ventures while at Cisco. Jeff is a member of IFA and past member of TEI while a Cisco Systems tax executive, speaking on international tax topics for TEI and TCPI while a corporate tax executive.  He was a speaker at the International Tax Conference held by the India and USA branches of IFA in New Delhi in 2006 and in Washington DC in May, 2009.  Jeff has extensive experience with foreign tax audits, competent authority procedures and APAs.  Jeff co-authored an article in Tax Management International Journal on US Multinationals Investing into India and a three-part article for investing into China.  He has also co-authored an article on the new Contract Manufacturing regulations which was published in May, 2009 in TMIJ.  Jeff is a licensed California CPA.  He graduated with a BS in Accounting from the University of Illinois Urbana-Champaign campus.

    Elizabeth Lieb practices in the area of corporate and international tax planning at Baker & McKenzie in Palo Alto, CA. Ms. Lieb’s practice emphasizes a variety of international tax planning matters for multinational corporations, including structuring and implementing international operations, such as intangible property arrangements, and manufacturing and services supply chains. She also advises on subpart F planning, tax treaties, and the tax aspects of multi-jurisdictional post-acquisition integrations and other corporate reorganizations. Prior to joining Baker & McKenzie in 2007, Ms. Lieb worked as a tax associate in the Menlo Park office of Shearman & Sterling LLP and as Attorney Advisor to the Honorable Carleton D. Powell of the United States Tax Court. Ms. Lieb has lectured on Section 956 Investments in United States Property for Bloomberg/BNA CITE, and Income Tax Treaties for Networking Seminars.  Ms. Lieb is the co-author of Changes to the “Tax Shelter” Rules After the American Jobs Creation Act of 2004, Practical TaxLawyer (February 2006). Ms. Lieb is a member of the Taxation Section of the American Bar Association and the State Bar of California Taxation Section. She received her LL.M. (Taxation) from New York University School of Law; her J.D. cum Laude from California Western School of Law; and her B.S. (with honors) from the University of Iowa. 

    Reza Nader is a member of Baker & McKenzie’sNorth America Tax Practice Group in the New York office, where he works on international tax planning and transactions. He is an active participant at both in-house and external seminars and conferences. Mr. Nader has also worked on various pro bono matters, including work with international development organizations. Mr. Nader has experience advising clients on international mergers, acquisitions, and dispositions, supply chain restructurings, and joint ventures and alliances. He also advises clients on dispositions of US real property interests, bankruptcy reorganizations, and income tax treaties, including competent authority matters. Mr. Nader served as an adjunct professor in Outbound International Taxation at the Georgetown University Law Center in 2011. He received his LL.M., in Taxation, with distinction, Deans List, Georgetown University Law Center; his J.D. from Emory University School of Law; and his B.A. with honors from Schulich School of Business in Toronto, Canada.

    Klaus Oehring is the National Director of Transfer at UHY Advisors. Klaus is a CPA with 30 years of industry and public accounting experience. He practices in all areas of U.S. income taxation with special emphasis on international tax, transfer pricing and related tax accounting matters including ASC 740. Klaus has extensive experience preparing U.S. and foreign contemporaneous transfer pricing documentation and handling Advanced Pricing Agreements, Competent Authority and tax audit defense matters. Previously, Klaus worked as the International Tax Director for ClubCorp Inc., an International Tax Specialist for Dresser Industries, Inc., the Director of Transfer Pricing at Gardere Wynne Sewell, and as a Senior Manager for KPMG in Calgary, Canada, and Dallas, Texas. At Dresser, he was responsible for the annual tax footnote, directing the implementation of FAS 109 and establishing and modifying Dresser's worldwide transfer pricing strategies including the designing of contemporaneous transfer pricing documentation. He also directed the implementation of various intercompany arrangements, assisted division controllers in establishing intercompany prices for goods and services, and resolved several multi-country tax audits. At ClubCorp, Klaus was responsible for similar matters in the leisure and hospitality industry, including negotiating two Advanced Pricing Agreements. In addition, he has been involved in due diligence and tax planning related to several corporate mergers. Klaus is a frequent speaker at international tax and transfer pricing seminars. He developed a 2-day seminar titled “U.S. Transfer Pricing Primer” for Bloomberg BNA which deals with practical approaches to most common intercompany transfer pricing arrangements.

    Ben Olivas is a partner in the International Tax group at DLA Piperin San Jose, CA. He concentrates his practice in international tax and operational structuring, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, post-acquisition integration, and tax controversy. He has worked extensively with US companies doing business in various parts of the world, as well as foreign companies expanding their US operations.  Prior to joining the firm, he spent fifteen years at PricewaterhouseCoopers LLP, including seven years as a partner in the international tax group. As a partner in a Big 4 accounting firm, he dealt with international tax issues from both planning and tax provision perspectives. 

    Narelle MacKenzie is a well known international tax consultantwith over 25 years of experience in international taxes, Her experience working with, or for, multinational companies enables her to develop strategic and practical solutions to minimize worldwide tax burdens. Ms. MacKenzie is also an International Tax lecturer at San Diego State University (SDSU), first appointed in 2007. She is located in San Diego, CA and works with CPAs, attorneys, and in-house tax departments worldwide. She has worked in both public accounting and industry for employers such as Goodrich Corporation (a Fortune 500 company that was acquired by United Technologies), PricewaterhouseCoopers LLP, and Toyota Australia. Her business experience has covered diverse industries and activities, including supply chain activities and initiatives, identification and implementation of new manufacturing facilities, establishing representative offices, secondment arrangements, customer sales and support initiatives and general cross-border issues.  As well as lecturing at SDSU, she is a highly sought after speaker, course instructor and guest lecturer and has presented at many and diverse conferences including CalCPA, the ABA, AWSA and PwC. She is a Past President of CalCPA (San Diego chapter), and currently serves on the Audit Committee for St James by the Sea, La Jolla.  Ms. MacKenzie is an Australia CPA and a California CPA. 

    Michael J. Masciangelo is a partner in and member of Ernst & Young LLP’sInternational Tax Services practice in Houston. Michael is responsible for leading Ernst & Young’s global resources in designing and implementing a variety of strategies for our clients. Michael has worked with several Ernst & Young offices since joining the firm in 1995 and has over 17 years of experience in corporate and international (inbound and outbound) tax.  Michael has concentrated on both outbound and inbound clients across a broad range of industries.   In addition to his specific client serving role, he serves as the firm’s International Tax Think Tank Leader for the Southwest Sub Area and performs a similar role for other international tax technical initiatives within the firm.  Michael has been actively involved in advising our clients on opportunities to reduce their global tax burdens and minimization of risk.  His work includes advising on internal and external restructurings, financing/repatriation, acquisitions, joint ventures, foreign tax credit matters, and tax implications of global supply chain initiatives. He has also been involved with complex tax provision reviews, research of and advising on tax accounting issues and has extensive experience in advising on matters of foreign source income and expense allocation and apportionment. Michael has B.B.A in accounting from Kent State University and Master of Taxation from the University of Denver. He is a certified public accountant licensed in the states of Ohio, Illinois, and Texas.  He has instructed at internal seminars and many US and European client and educational seminars.

    James Prettyman is a partner in the Mergers and Acquisitions Group inPricewaterhouseCooper's Houston office.  Previously, James was an M&A partner in PwC's Washington National Tax Services office.  He specializes in corporate transactions and consolidated returns and cross border restructuring.  James has over 20 years of experience in public accounting.  James provides consulting services to the clients on numerous acquisitions, dispositions, restructurings and tax planning projects.  These projects include optimizing the tax position of the clients on acquisitions and dispositions, tax basis and earnings and profits studies, section 382 analyses, and private letter ruling requests.  He also has experience in cross-border restructurings, restructuring of consolidated groups in anticipation of REIT IPOs, internal spin offs, and several acquisition and disposition related consulting projects.   In addition to his client responsibilities, Mr. Prettyman has participated in a number of panels for TEI, ALI/ABA and other organizations. James received his Bachelors of Business Administration in accounting and a Masters in Professional Accounting with an emphasis in tax from the University of Texas at Austin.  He is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.  He was a member of the AICPA Corporation and Shareholder Technical Resource Panel. 

    Amy Ritchie is currently the Southwest Region International Tax Leader based in Houston at Ernst & Young LLPand was most recently the Tax Market Leader for the Austin office.  She has over 16 years experience working with both U.S. and foreign multinational clients in various industries including technology and manufacturing.  As an international tax advisor for audit and non-audit clients, Amy’s experience includes international mergers and acquisitions, foreign restructuring, international compliance, foreign tax credit utilization, inbound investments, tax treaty analysis and foreign currency issues as well as a strong background in tax accounting. Prior to joining the E&Y Austin office in 2005, Amy spent eight years with E&Y in the San Francisco Bay Area. Amy received a BA in Economics and a Masters in Accounting from Rice University in Houston, Texas.

    Brad Rolph is the National Leader of Grant Thornton's transfer pricing practice in Canada. Mr. Rolph has been providing transfer pricing consulting services to multinational companies for the last 18 years. He was the first economist hired by any of the Big Four accounting firms in Canada to practice transfer pricing exclusively. Euromoney's Legal Media Group recognized Mr. Rolph as one of Canada’s leading transfer pricing advisers in its 2013 "World's Leading Transfer Pricing Advisers" publication.  His areas of expertise include planning, implementing and documenting intercompany transactions for tangible goods, services and intangibles in a tax-efficient, defendable manner (“TESCM”); building models to price complex financial transactions; resolving audit disputes at the field, appeals and Competent Authority level; negotiating advance pricing arrangements (“APA”); and providing litigation support. Mr. Rolph has served companies based in Canada, the United States, England, Ireland, Finland, France, Germany, Sweden, Saudi Arabia and Japan. He has dealt with issues in the following industries: Aerospace, Mining, Metals and Minerals, Pulp and Paper, Transportation, Heavy Manufacturing, Steel, Utilities, Automotive, Chemical, Pharmaceutical, Food and Beverage, Electronic, Financial, Wholesale Trade, Apparel, Consumer Goods and Entertainment. He also has extensive experience with Japanese trading companies and web-based businesses. Mr. Rolph is a frequent speaker and commentator on transfer pricing matters. Mr. Rolph has been published in International Tax Review, Euromoney and Tax Management International. Mr. Rolph received his MA in Economics from Queen’s University and his BA in Economics from Wilfrid Laurier University. 

    John G. Ryan is a Partner at Bingham McCutchen LLP in Silicon Valley.  John focuses his practice on tax planning and audit defense, most notably in connection with international transactions and the development and use of intellectual property. Ranked in Chambers USAas a leading tax lawyer in California, he is described as “a one-stop shop…he can analyze problems from all angles,” with clients praising his “broad knowledge of international tax and transfer pricing matters,” as well as his “responsiveness and accessibility.” John is a frequent speaker at professional organizations, discussing topics such as research and foreign tax credits, international restructurings, and transfer pricing. He has also taught courses on international and partnership issues for the LL.M. program at Golden Gate University. John has written numerous articles on tax for various publications.  John is honored by the Chambers USA, America’s Leading Lawyers for Business, Tax: California (2011–present); by Legal 500, Tax; Tax Controversy (2012–2013); and is voted Best Lawyers, Tax Law (2013–2014). John received his Juris Doctor from Stanford Law School; His Doctor of Philosophy from the   University of California, Berkeley and his Master of Science from the University College Dublin

    Margaret A.R. Shulman is a Executive Director in Ernst & Young LLP’sInternational Tax Services group in New York. She has recently joined E&Y from an international law firm. Margaret’s experience also includes having clerked at the U.S. Tax Court for the Hon. David Laro. Prior to switching to a career in tax, Ms. Shulman was a corporate lawyer, and, prior to that, a professional musician. Ms. Shulman counsels corporate and individual clients on the U.S. federal income tax aspects of a variety of cross-border business transactions and restructurings. She also has experience in providing a collaborative advice on the tax planning involving several foreign jurisdictions. Corporate clients benefitting from Ms. Shulman’s advice include both public and private companies conducting business in a variety of industries, including pharmaceuticals, consumer products, and media and entertainment. Ms. Shulman holds a B.A. in music and psychology, a J.D., and an LL.M. in Taxation. She is an author of several articles on international tax topics. Margaret is admitted to practice law in Michigan and in the District of Columbia, and is a member of the American Bar Association and of the International Fiscal Association.

    Jessica A. Silbering-Meyer is a member of Ernst & Young LLP’sInternational Tax Services practice for the Northeast Sub-Area and is based in New York. Jessica’s practice covers the areas of international tax planning, including cross-border restructurings, Subpart F and repatriation planning, supply-chain structuring, and other inbound and outbound matters. Jessica’s client portfolio includes companies in Media & Entertainment, Telecommunications, and Consumer Products industries. Prior to joining Ernst & Young LLP, Jessica worked as an associate at PricewaterhouseCoopers LLP in New York. Her primary areas of practice there included international tax planning involving financial transactions for hedge funds, fund of funds and private equity groups. Jessica holds a Bachelor of Arts, cum laude, in Political Science from Bryn Mawr College, a Juris Doctor from Hofstra University School of Law, and a Masters of Business Administration in Finance from Hofstra University Frank G. Zarb School of Business. She is admitted to practice law in the State of New York. 

    Gabriel Taubenfeld is a Senior Manager in Ernst & Young LLP’sInternational Tax Services practice. He advises multinational corporations and private equity investors on a variety of international tax matters related to cross-border transactions and general international tax planning.   Gabe has advised on numerous cross-border M&A transactions, financing and reorganizations, ranging in value between $10m and $23b across a broad range of industries. In this regard he is experienced in transaction structuring, tax modeling, due diligence and pre and post-transaction restructuring. Gabe also regularly assists both US and foreign multinational clients with all aspects of US international tax planning and compliance. In particular, he has assisted clients with foreign tax credit planning, tax-effective cash repatriation planning, Subpart F planning, tax treaty issues, US trade or business issues and effectively connected income.  Gabe received a B.A. in Accounting from the City University of New York at Queens College, a J.D. from Fordham University School of Law and an LL.M. in Taxation from New York University School of Law. He is a member of the Tax Section of the American Bar Association and is a certified public accountant in New York.

    Steve Weertsis a partner in the Tax practice of DLA Piper LLP in Los Angeles.  He is experienced in international tax and transfer pricing matters. He concentrates in international business and tax planning. He has advised on the tax aspects of international joint ventures, cross-border mergers and acquisitions, post-transaction integration, international corporate finance, capital market transactions, and general international tax planning matters. Mr. Weerts comes to DLA Piper from KPMG, where he was a manager in the International Corporate Tax Services group. He has also worked with the IRS Chief Counsel’s Office and in the tax department of Ascent Media Group.  Mr Weerts received his LL.M., Taxation, from Loyola Law School; his J.D., Loyola Law School; and his B.S., Accounting, from Loyola Marymount University.

    John T. Woodruff is a partner in the law firm of McDermott Will & Emery LLPand is based in the Firm’s Houston office.  John advises clients on all aspects of international tax, transfer pricing, and tax issues related to cross-border mergers, acquisitions and restructurings.  He regularly counsels clients on issues related to the U.S. foreign tax credit, subpart F, U.S. trade or business/permanent establishment determinations, treaty-based positions, transfer pricing strategies and strategic tax-related planning for international investments and financings.  Drawing on his years of experience in private practice and in major accounting firms, John structures acquisitions, dispositions, public offerings, reorganizations, restructurings, repatriations, and insolvency transactions.  He represents multinational clients operating in a broad range of industries, with a particular focus on energy clients involved in exploration and production, oilfield services, offshore drilling, maritime, oilfield manufacturing and engineering, procurement, and construction.  John is a regularly featured speaker at conferences, seminars, meetings and other events sponsored by the American Bar Association, the Tax Executives Institute, the American Petroleum Institute, the Houston International Tax Forum, and the CPAmerica Tax Conference, among many other organizations.  He has also authored and co-authored articles and online content for a range of legal and industry publications, including Tax Notes International. John is a member of the State Bar of Texas, the State Bar of Virginia, the International Bar Association, the American Bar Association, the Houston Bar Association, the Houston Tax Roundtable, the Houston International Tax Forum and the World Affairs Council of Houston. John is admitted to practice in Texas and Virginia. Mr. Woodruff earned his LL.M. from Georgetown University Law Center; his J.D. from University of Tulsa College of Law and his B.S. from Oklahoma State University.

    Steven C. Wrappe is in KPMG 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.