The International Tax Group
Bill Amon is a Managing Director at Anderson Tax in Los Angeles. Bill has over 30 years of experience in corporate and international taxation. He advises corporations, partnerships and limited liability companies on a broad variety of business and tax matters, including: Mergers and acquisitions planning and consultation; Restructuring planning; Accounting methods; Transfer pricing; International tax planning and consultation. Bill earned his BS from the University of Santa Clara and his JD from the University of Santa Clara, School of Law. Bill is a member of the American Institute of CPAs; California Society of CPAs; California Bar Association; Advisory Board Member, Santa Clara School of Law-International Law; Adjunct Professor of Tax, Golden Gate University’s Master’s Program; Member, Los Angeles International Tax Forum.
John Apuzzo is an International Tax Senior Director located in the Los Angeles office of PricewaterhouseCoopers LLP, serving clients in the Western Region. He has over 16 years of international taxation experience. 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. 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 is a principal at KPMG LLP. 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 KPMG, 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. Sherif holds a PhD in economics from Fordham University and has spoken at numerous conferences and seminars regarding transfer pricing.
Andrew Bernard is a Managing Director at Andersen Tax in Philadelphia. Andrew has over 29 years of experience with U.S. and international tax matters. His international practice areas include taxable and tax-free international mergers, acquisitions, and restructurings for U.S. and non-U.S. based corporations, partnerships and S corporations. Representing clients before U.S. and non-U.S. tax authorities. Andrew has substantial experience in serving U.S. and non-U.S clients in many industries, including manufacturing, technology, financial services, real estate, pharmaceutical, energy, professional services, private equity, and media and entertainment. Andrew is part of the National Tax Office, serving as a resource for international taxation. Andrew received his BSBA (Accounting) from Geneva College and his MS (Taxation) from Georgetown University.
Rivi Biton is a Senior Manager in Ernst & Young LLP’s International Tax Services and specializes in International Tax Quantitative Services in New York. She has been working at E&Y for over 10 years. Rivi’s experience also includes Federal and Individual Taxation. Ms. Biton is also an adjunct accounting professor and teaches various classes including corporate taxation and auditing. Rivi is a C.P.A in the state of NY, she holds an Accounting and Finance B.S as well as a J.D. She is licensed attorney in NY and is an admitted in the Second Circuit Southern District of NY.
Trevor Blumenfeld is a Manager at the KPMG LLP in New York, NY. Trevor is a Manager in the International Tax practice of KPMG’s New York office. Prior to joining KPMG in 2011, Trevor was an auditor at another accounting firm. Trevor provides U.S. tax consulting and compliance services to U.S.- and non-U.S.-based multinational companies, including advice regarding cross-border mergers and acquisitions and related U.S. international tax filing obligations. Trevor received his LL.M. in Taxation from New York University and his J.D. from St. John’s University School of Law.
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 to name a few. 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.
Christopher Booth is a Director in the International Tax Service Line with Deloitte in San Diego. Chris has more than 16 years of experience in public accounting serving a variety of multinational clients in the West Region including multinational public and private companies in a variety of industries. He has experience with inbound and outbound taxation including financial reporting for income taxes (ASC 740) for both attest and non-attest clients. Chris graduated from San Diego State University with an MS and BS in Accounting with an emphasis in Taxation. Chris is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Brandon Bonzheim is a Tax Senior Manager at Deloitte Tax LLP in Chicago, Brandon advises U.S. and foreign-based multinational corporations in a variety of industries on a broad range of international tax issues, including cross-border mergers and acquisitions, dispositions, spin-off transactions, restructurings, cash repatriation planning, foreign tax credit utilization planning, subpart F and passive foreign investment company issues. He is a licensed member of the New York Bar. He received his B.A. from Michigan University; his J.D. from Hofstra University and his LL.M. in Taxation from New York University School of Law.
Jeff Borchers is a Tax Director with the Federal Tax practice at KPMG LLP in the Houston office. He has both public accounting and legal experience advising clients on various tax matters in the engineering and construction, energy and real estate industries. Jeffery has 18+ years of financial experience which includes leading the Tax and Treasury functions at Willbros Group, Inc., working for the IRS Office of Chief Counsel as a tax advisor and advising clients in various tax matters while at KPMG and DLA Piper in Chicago.Jeffery received his B.S. (Accounting) from DePaul University; his J.D. from John Marshall Law School. He a member of the Illinois State Bar and also passed the CPA examination.
Anne Bouse is a Senior Manager at Ernst & Young LLP in the International Tax Services practice in Chicago. Anne has experience working on projects for multinational corporations in the areas of international tax compliance, provision and consulting, including foreign tax credit planning and repatriation planning. Anne received a Bachelor of Business Administration in Accounting from Saint Mary’s College and completed her Masters of Science in Taxation from the University of Illinois. She is also a Certified Public Accountant in the state of Illinois.
Howard Braithwaite is a Director in KPMG’s Philadelphia International Tax practice. He has approximately 35 years of experience advising clients on U.S. federal income tax matters for a variety of transactions and issues. Howard has devoted his entire career with Big Four accounting firms, both with KPMG and one other firm. He has served clients in a number of industries including pharmaceutical companies, insurance companies, and manufacturing companies. He recently returned to the Philadelphia market after devoting approximately 15 years in the Washington, DC National Tax office with the other Big Four firm. The majority of his time has been focused in the mergers and acquisition arena, both third party transactions and internal restructurings precipitated by changes in business operations. He has significant experience with corporate tax matters, S corporations, consolidated returns, U.S. international tax matters, partnership issues, and practice and procedure rules in general. He has published articles in external tax journals and has been an instructor or co-instructor at in-house technical tax training courses for many years.
Chi-May Brewer is an economist in Baker & McKenzie's Houston office. She has managed transfer pricing studies for multinational corporations on a broad range of transfer pricing issues and in a variety of industries. Ms. Brewer also performs financial modeling and analyses. Prior to joining Baker & McKenzie, she worked at Big Four accounting firms and in the airline industry where she performed many financial and economic analyses. Ms. Brewer works extensively on global transfer pricing issues, including planning intercompany pricing, overhead allocation, restructuring intercompany arrangements, and documenting tangible, intangible, and services transactions for tax purposes. Her experience covers a wide variety of industries, including oil and gas services, contract research organizations, chemicals, equipment manufacturers, and engineering and related services. In addition, Ms. Brewer has performed many financial modeling and economic analyses, including valuing the returns of internal projects, as well as forecasting company and industry financial results. Ms. Brewer received her M.B.A. from Georgetown University McDonough School of Business and her B.A. (cum Laude) from the University of Pennsylvania.
Margaret Brown is a member of Ernst & Young’s Transfer Pricing and Economics practice for the Southwest Region. She is based in Houston, Texas. Margaret received a Master of Arts and Bachelor of Arts in Economics from the University of Southern California. She is a member of the California Board of Certified Public Accountants, American Institute of Certified Public Accountants and National Association of Business Economics. Margaret has more than nine years of transfer pricing experience with EY and has served clients in a wide variety of industries, including oil and gas, energy, information technology, entertainment, pharmaceuticals, retail, mining and chemical industries. Margaret assists clients with many transfer pricing issues, including transfer pricing planning, controversy, advance pricing agreements, global transfer pricing documentation, headquarter cost analysis, operating model effectiveness planning, intangible property issues, economic modeling and general economic advisory. Margaret has assisted companies with transfer pricing documentation and planning studies in many countries, including Australia, Canada, Chile, China, France, Denmark, Germany, India, Italy, Mexico, the Netherlands, Norway, Russia, Singapore, Taiwan, the UK and the US.
Greg Bryant is a lawyer and certified public accountant with over 25 years of experience as a Big 4 National Tax Director and as VP of Taxes and Shared Services for a Fortune 1000 multinational. Prior to founding BILTgroup, Greg was most recently a Partner and Chair of International Tax at Williams Mullen. Having worked hands-on in many areas of international taxation, law and accounting both as an executive in a Fortune 1000 company and as a legal and tax advisor, 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 answers the “how to” questions. As Outside Corporate Counsel for several multinational clients, he has negotiated, drafted and deployed multinational supply chain framework agreements, structured international supply chain networks, and leveraged the value chain of companies to reduce tax risk and improve cashflow. He has represented companies in many US and non-US tax controversies, including tax litigation cases in Holland and Germany. Greg earned his accounting and Juris Doctor degrees from the University of South Carolina. He has his LLM in Taxation from Georgetown University Law Center. He is licensed as a Certified Public Accountant in Maryland and North Carolina, and is a licensed attorney in Pennsylvania. Greg is a member of the American Institute of Certified Public Accountants (AICPA) and International Fiscal Association (IFA). Greg is also a Regional Vice President of IFA and a founding member of the Triangle IFA chapter. His law practice is entirely international and federal law.
Oscar Burakoff is a principal economist in DLA Piper's Tax practice, based in San Diego. He focuses his practice on transfer pricing and intangible property valuation. Mr. Burakoff has experience managing global transfer pricing projects covering all types of transactions, including cost sharing, licensing, intercompany services and financing. Specifically, Mr. Burakoff has experience in: Analyzing numerous transactions, including tangible property transfers, intangible property transfers, intercompany loans and various services transactions such as contract manufacturing, contract research and development and management services; Preparing studies documenting the arm’s length nature of intercompany prices in various industry sectors to satisfy US, OECD, and local-country documentation requirements in countries including the United States, the United Kingdom, Canada, France, Mexico, Spain, Australia, Switzerland, Germany, Hungary, Poland, Taiwan, Italy, the Netherlands, Argentina and the Czech Republic; Valuing pre-existing intangibles to determine buy-in payments for companies implementing cost sharing arrangements that involve the development of technology and/or marketing intangibles; Valuing trademarks for tax/transfer pricing purposes in various industry sectors; Performing business optimization strategies, including recommending royalty rates related to design and marketing intangibles and advising in the restructuring of transfer pricing systems after a merger or acquisition. Before joining DLA Piper, Mr. Burakoff was a vice president at Duff & Phelps, where he worked with Clarke Norton, Ray Brown and Paul Burns. Mr. Burakoff received his B.A. in Business Administration with concentration in Corporate Finance at University of Southern California.
Kevin Burke is a Principal in Ernst & Young’s International Tax Services group in Boston. Kevin has over 15 years of transfer pricing experience with Ernst & Young and currently assists Northeast Area clients with a range of international tax planning, compliance, due diligence and controversy support transfer pricing services. Kevin has substantial experience in advising companies on the valuation of intellectual property in connection with implementation and documentation of global supply chain engagements. Prior to joining Ernst & Young's Northeast Area, Kevin was with the Firm's National Tax practice in Washington D.C. Kevin graduated from Trinity College in Hartford, Connecticut in 1994 with a B.A. in Economics and is an accredited member of the American Society of Appraisers specializing in business valuation.
Sarah Busker is an international tax senior manager in Ernst & Young’s Houston office. Sarah has over 10 years of experience in international tax compliance and reporting. Areas of expertise include: tax reporting of foreign subsidiaries, US tax reporting of foreign corporations, foreign bank account reporting, foreign tax credit reporting and Section 987. Other areas of experience include real estate partnerships and federal tax compliance. Sarah joined Ernst & Young in 2002 upon her completion of the Professional Program in Accounting at Texas A&M University. Sarah holds a BA in Business Administration and a MS in Taxation. She is a Texas CPA and a member of the AICPA.
Amy Cannefax is a Sr. Manager in the Federal Tax Practice at KPMG LLP, specializing in Tax Transformation and Outsourcing. Amy has over 30 years of tax and management accounting experience in the Financial Services Industry with over 13 years as the Tax Director of a large financial services company. Amy’s combination of tax and management accounting experience provides her with a broad perspective of the issues faced by tax departments and CFO organizations. Her experience includes: Federal, State and local taxation of insurance companies, banks, mutual funds, real estate transactions and partnerships; Life/Non-life consolidated return filing; GAAP and Statutory tax provision preparation; Information reporting; Payroll; Change Management team lead for a CFO transformation effort; Project Leader for implementation of a new payroll system; Business Valuations. Amy received her B.B.A. from University of Texas; is a CPA; Certified Management Accountant (CMA) and Accredited in Business Valuation (ABV).
Alan Cathcart is a senior director in KPMG’s Mergers & Acquisitions Tax Practice, with more than 30 years’ experience in international transactions. Alan has advised US and foreign corporations, private equity funds, and sovereign wealth funds with respect to taxable and tax-free acquisitions, post-merger integration, international deployment of intellectual property, worldwide effective tax rate management, and an extensive variety of US international tax topics including subpart F, foreign tax credit, and foreign currency gains and losses. He also plays a significant role in KPMG’s internal training programs and is a regular speaker in external forums. He has worked with companies in virtually every industry.
Rui Che is a Senior Manager in the Philadelphia office of KPMG LLP’s Transfer Pricing Practice with over 7 years of experience in Transfer Pricing. Her practice focuses on development of economically supportable transfer pricing policies and the execution of sustainable tax planning with effective tax rate benefits, together with the associated implementation, compliance and documentation, financial reporting, and controversy assistance. Rui’s specific areas of focus include complex IP transfers, restructuring of supply chain, etc. Rui received her MA in Economics from the Ohio State University and her BA in Finance from Peking University.
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.
Chuck Chubb is the Managing Director at Anderson Tax 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 regardingASC 740matters. Chuck attended Bloomsburg University, where he received his BSBA in Business Administration – Accounting.
Robert A. Clary II is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Chicago office. Rob’s practice focuses on international and domestic tax planning for multinational companies, including advising clients with respect to the tax aspects of domestic and cross-border acquisitions, divestitures, spin-offs, corporate restructurings, joint ventures and other corporate activities. Rob also represents multinational enterprises and other clients in international transfer pricing and tax controversy matters relating to cross-border operations, investments and transactions. Rob was selected as a 2013 Illinois Super Lawyers Rising Star. Prior to joining McDermott, Rob worked for a “Big Four” accounting firm in the mergers and acquisitions group of the Washington, D.C., national tax office. Rob is an Adjunct Professor at the Chicago-Kent School of Law, where he teaches Taxation of International Transactions. Rob is admitted to practice in Illinois. Rob received his J.D., magna cum laude and Order of the Coif, from the University of Miami School of Law; his LL.M. from
Jason R. Connery is a principal at KPMG LLP in the International Tax group of the Washington National Tax practice. He provides tax advice to foreign-based multinational companies, including insurance companies, and private equity funds on a wide range of matters, including branch taxation, FIRTPA, sourcing of income, allocation and apportionment of expenses, foreign currency taxation, and income tax treaty issues. He also provides tax advice to U.S.-based multinational companies on matters involving offshore earnings deferral, foreign tax credits, subpart F, and foreign currency and interest rate risk management in offshore treasury centers. Jason has worked extensively in the area of cross-border finance and financial products. He is a frequent speaker and writer on U.S. international tax issues. Jason rejoined KPMG LLP in 2006. Prior to that, he was a director of the Structured Finance Group at an investment bank in New York City, where he developed and implemented cross-border financings for the investment bank. Previous to working at the investment bank, Jason was a senior manager in the International Corporate Services group of KPMG’s Washington National Tax practice. Before that, Jason was a member of KPMG’s Financial Services practice in New York City, working primarily with foreign-based financial services institutions engaged in business in the United States. Jason earned his LL.M. from New York University, his JD, cum laude from The John Marshall Law School, and his BS in accounting, with honors, from University of Florida.
Brendan Cox is a Partner at Ernst & Young LLP, in the East Central Sub Area Federal Tax Practice, with over 17 years experience as a tax professional and over 9 years of specialized federal tax accounting methods experience. The issues Brendan has focused on include tax accounting for income and deductions under the all events test, tax accounting for advance payments, capitalization issues, distinguishing a change in facts from methods and Section 199 (the domestic manufacturing deduction). Brendan has successfully managed the implementation of several large federal tax projects, including multi-phase, comprehensive “turn-key” implementations. Many of these projects also included mining and manipulating substantial amounts of data using various technology tools. In addition, his projects have incorporated statistical sampling processes where appropriate and representing those results to the IRS. Brendan has spent substantial time working with clients in the manufacturing, telecommunications, pharmaceuticals, computer software, utilities, and media industries. Brendan is a frequent speaker on federal tax matters. He has addressed the Tax Executive Institute and internal Ernst & Young education programs and client seminars. Brendan holds a Bachelor of Science degree from Villanova University and an MBA from the University of Notre Dame. Brendan is licensed by the State(s) of Maryland, New Jersey, and Pennsylvania as a Certified Public Accountant.
Peter Crocco is a Managing Director at Andersen Tax in New York. Prior to joining Andersen Tax, Peter was Managing Director at True Partners and Affinity Tax Group. He also worked at two of the Big 4 accounting firms. Peter is a highly experienced tax practioner that assists clients in minimizing risk with respect to tax reporting under ASC 740. Peter received his LL.M. from American University, Kogod School of Business and his B.A. from Long Island University – C.W. Post Campus.
John Crucs is a managing director in the International Tax group at KPMG LLP where he provides tax consulting services to a broad range of multinational clients. He has over sixteen years of tax experience based out of Boston, New York, and New Jersey. His practice involves advising clients on structuring and managing their global operations in a tax efficient manner. In addition to global tax planning, John has experience with other tax matters including preparing and auditing U.S. corporate tax provisions, preparing and reviewing U.S. corporate international tax compliance, and responding to audit inquiries from U.S. and foreign taxing authorities. Prior to joining KPMG, John was a tax director at LVMH Moët Hennessy Louis Vuitton Inc. where he was responsible for U.S. tax planning and operations. Prior to that, he was a senior manager in the international tax services group at Deloitte. John received his B.A. from The College of the Holy Cross in 1995 and his J.D. from Boston College Law School in 1998. He is admitted to the New York Bar and the Massachusetts Bar.
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.
Steven M. Davis is a Principal in the International Tax Services group at KPMG LLP’s New York City office with over 22 years of international tax experience. Steven is the East Regional Leader of Deloitte’s Business Model Optimization (BMO) practice and is a member of the global BMO leadership team. The BMO practice focuses on helping multinational companies across all industries integrate their operational and tax planning in a scalable and sustainable way to help business leaders make more effective decisions on an after-tax basis. Steven has extensive experience assisting US and non-US multinational organizations in identifying and implementing strategies for minimizing global taxation. These strategies encompass matters related to the migration of intangibles, supply/value chain planning and other business transformation strategies. In this regard, he has significant practical experience in the assessment, design, implementation and post-implementation maintenance of global strategies to achieve sustainable tax-aligned operational synergies for some of the firm’s key clients. An integral part of his experience includes project management and effective resolution of critical business, tax and legal issues, through careful and pro-active coordination between the client’s financial and operational stakeholders driving such business transformation strategies. Prior to joining Deloitte, Steven was the International Tax Director at Loral Space & Communications Ltd. Prior to that, Steven practiced tax law in the New York City office of the law firm of Akin, Gump, Strauss, Hauer & Feld, LLP. Steven obtained his LL.M. (Taxation) from NYU School of Law, his JD from Hofstra Law School and his BS (Accounting) from Syracuse University. Steven also is a frequent lecturer on topics related to IP and supply chain planning.
Paul De Pasquale is an associate in Baker & McKenzie's Tax Practice Group. Paul's practice focuses on international tax, wealth management, and compliance matters. Paul's typical clients include financial institutions, high-net worth individuals and families, family offices, private banks, trustees, and non-financial entities. He focuses on US and international taxation, FATCA, withholding taxes, information reporting, trust and succession planning, pre- and post-immigration tax and estate planning, and relocations. Paul received a BA in Government from the College of William & Mary and his JD from the University of Michigan Law School. Paul has previously worked in the Firm's Zurich and Hong Kong offices.
Ghansham Dhanak is a Director in the International Tax Services practice in the New York office of PricewaterhouseCoopers LLP. Ghansham is in the Quantitative Solutions (QS) practice, a group within the ITS practice that specializes in providing quantitative tax services to multinational companies. Ghansham 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. Ghansham 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. Ghansham received a Masters of Science Degree from Baruch College, CUNY. He holds the Certified Public Accountant designation and is a member of the American Institute of Certified Public Accountants.
Matthew J. Donnelly is an associate in the Chicago office of Skadden, Arps, Slate, Meagher & Flom LLP. Matt 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, transfer pricing, foreign tax credit planning, and various types of financings. Matt received a L.L.M. in taxation from Northwestern University School of Law (with honors), a J.D. from the University of Iowa College of Law (with high honors; editor in chief, Iowa Law Review; Burton Award), and a B.S. from Northwestern University. He is admitted to practice in Illinois.
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.
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.
Greg W. Featherman is a Senior Manager in KPMG’s Washington National Tax Corporate practice and a member of KPMG’s Washington National Tax International M&A Initiative. Mr. Featherman 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, and consolidated return matters. Prior to joining KPMG, Mr. Featherman was an associate in the international law firm of Dewey & LeBoeuf LLP. Mr. Featherman has spoken on subjects in his practice area for various groups, including the American Bar Association and the Wall Street Tax Association. Mr. Featherman has represented: Bank of America Corporation, General Electric Company, General Motors Company, NCR Corporation, Omnicare, Inc., Pfizer Inc., Safeway, Inc., The Talbots Inc., and The Walt Disney Company. Mr Featherman recived his LLM, Taxation, from Georgetown University Law Center; his JD from George Washington University Law School and his BA from Lafayette College.
Andrew R. Fisher is a Director in Deloitte Tax LLP’s U.S. Transfer Pricing practice, currently based in the Los Angeles office. He has over 30 years experience in public accounting in both the U.S. and Australia. Since 1994 Andrew’s work has focused on transfer pricing, assisting corporations to understand, address and explain their transfer pricing arrangements. Andrew has considerable experience dealing with revenue authorities in Australia (the Australian Tax Office), the US (US Internal Revenue Service) and other countries in a range of situations including risk reviews, complex audits (examinations) and Advance Pricing Arrangements (APAs). More recently Andrew’s work has focused on examination of the steps in the value chain contributing to the total income of a business and structuring intercompany arrangements to appropriately reward the participants while managing the incidence of taxation. Examples of Andrew’s recent experience include: Implementation of a European regional distribution hub structure for a US based personal care products company; Advising U.S. companies in the management and resolution of IRS examinations; Advising US and Australian companies in relation to seeking competent authority relief to resolve tax disputes; Advising companies on a range of transfer pricing issues related to establishing business in foreign jurisdictions including issues associated with stripped risk distribution and commissionaire arrangements. He earned his Bachelor of Economics (Accountancy major) – Macquarie University; and his Masters of Taxation Law from the University of Sydney. He is a Certified Public Accountant; an Australian Chartered Accountant; and Fellow at Taxation Institute of Australia.
Paul Flignor is a Principal Economist with DLA Piper's Tax 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.
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, 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 served as an International Tax Director with national CPA firms.
Maureen Garcia is a member of Ernst & Young LLP’s International Tax Services (ITS) practice. She is based in Chicago, Illinois, and has more than 20 years of experience in the international tax area. Maureen joined Ernst & Young LLP in 1996. She provides quantitative international tax planning and is involved in foreign tax credit utilization planning, international tax compliance, Internal Revenue Service audit defense, earnings and profits studies, overall foreign loss studies, and computing the dollar approximate separate transaction method of earnings and profits. She has also been involved in the merger and acquisition restructuring of the foreign operations of US-based multinationals and has provided due diligence, implementation and data collection services. Maureen has experience with a variety of foreign tax credit software systems, including OneSource RS International, ITMS/FTMS and CorpTax – International. Maureen earned a Bachelor of Science in Accountancy and a Master of Science in Taxation from the University of Illinois. She is a certified public accountant licensed to practice in the state of Illinois. Maureen has spoken at internal and external international tax seminars in the Chicago area.
Victor Gatti is a Principal with KPMG’s New York Financial Services Practice (NYFS) and the New York Merger and Acquisitions Practice. Victor re-joined KPMG in October 2011, after a 5-year assignment as a Partner at Jones Day. While at KPMG, Victor has provided technical assistance to a wide variety of clients in a number of industries: Providing structuring and tax efficient post-acquisition implementation services in addition to general consulting structuring for a major Pharmaceutical company for over 12 years; Post-acquisition tax planning and consulting services for a number of private equity fund clients. While at Jones Day, Victor handled all areas of federal taxation, advised US- based multinationals in the US, assisted restructuring businesses to maximize their tax efficiency and assisted numerous clients in a variety of industries, including: Due diligence for mergers and acquisitions; Structuring cross-border joint ventures; Assist lenders and borrowers in reviewing credit agreements. Victor received his BA from University of Connecticut; his LL.M from NYU School of Law and his Juris Doctor from Western New England College School of Law.
Joseph Goncalves is a tax manager at KPMG LLP in Chicago and specializes in international taxation. He is responsible for providing tax services to U.S. multi-national and foreign-owned clients. He has over 8 years of international tax experience providing advisory and compliance services across several industries for both public and privately held clients. Joe is responsible for providing tax services to U.S. multi-national and foreign-owned clients. He has experience with corporations, hybrid entities, and reverse hybrid entities. Joe’s practice areas include, but are not limited to: foreign tax credit analysis, subpart F income and investments in U.S. property, transfers to and by foreign corporations, earnings and profits studies, withholding tax issues, bilateral treaty research, foreign currency, accounting for income taxes, and tax planning and structuring. Joe is a CPA in Massachusetts and Illinois and a member of AICPA and the Massachusetts Society of CPAs. He holds a BSBA with a concentration in Accounting from Boston University.
Christine Groen is a Senior Associate in Grant Thornton LLP’s Melville office. Christine has been with Grant Thornton LLP for almost two years and was previously at Deloitte Tax LLP. Christine has experience in serving both public and private corporations. Christine’s work focuses primarily on preparation and review of both quarterly and year-end income tax provisions, corporate tax compliance, and tax research. Bachelor of Science in Accounting at St. John’s University, Queens, NY; and Masters of Science in Taxation at St. John’s University, Queens, New York.
Joel Gross is a senior manager in KPMG’s International Tax practice based in Boston. Joel specializes in cross border mergers and acquisitions and international corporate taxation. Joel’s experience includes assisting multinational corporations with cross border acquisitions, financing structures, post transaction integration and structuring, cash repatriation planning and foreign tax credit planning. Prior to joining KPMG Joel was the Director of International Tax at Iron Mountain Incorporated, a publicly held $3.2 billion information management company headquartered in Boston. Joel also was a member of another Big 4 International Tax Services practice in Boston. During this time, Joel focused on technical tax issues arising in mergers and acquisitions, corporate divestitures, permanent establishments, post merger reorganizations and corporate restructurings. He also consulted on transfer pricing, cash repatriation strategies, subpart F income planning, withholding tax and income tax treaty issues, foreign tax credits and general international tax planning. Joel earned his J.D. from Western New England College School of Law and his LL.M. in Taxation from Boston University School of Law.
Aaron Grundman is an International Tax Partner and US Central Region Co-Leader of the Chinese Services Group at Deloitte Tax LLP in Chicago. He has over 20 years of experience serving US- and Asian-based multinational companies in various industries including consumer and industrial products, life sciences, and financial services. He specializes in advising companies on cross-border financing and cash mobilization, tax-aligned business model planning, foreign tax credit planning, and acquisitions, divestitures and reorganizations.
Alexander Hanhan is a Tax Managing 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 speaks on international tax matters for organizations such as the Tax Executives Institute, the Council for International Tax Education and Networking Seminars. Alexander earned his Masters of Laws in Taxation from New York University; his JD from Brooklyn Law School and his BA in Business Economics from University of Texas.
Mike Hardgrove is a partner in DLA Piper's Tax practice, based in Boston. He has provided international consulting, structuring and intangible transaction services to numerous public and private companies with operations throughout the world. Mr. Hardgrove focuses his practice on international taxation, concentrating in particular on global business structuring (GBS), a process of assessing international tax and operating cost exposures and then designing strategies for management of cost efficiency and key value drivers. Primary objectives of this process are to reduce the after-tax cost of capital and to lower the effective tax rate on profits from foreign activities. This includes: Assessing the tax risks inherent in international sales, distribution or manufacturing operations, and evaluating the international structure, transaction flow, value-chain and business transition plans; designing a strategy that can be integrated into international business functions such as trading companies, shared services centers, regional headquarters, procurement/sourcing offices, distribution centers, holding companies and/or treasury centers, and implementing principal operating models for European and APAC businesses, tax deferral structures, tax-efficient treasury management, entity restructurings, holding structures and acquisition structuring. Before joining DLA Piper, Mr. Hardgrove was with PricewaterhouseCoopers for more than 20 years, working in PwC offices in Brussels, San Jose/San Francisco and Seattle. He has served as PwC’s US leader for global structure alignment and as the national tax leader of the industrial manufacturing industry sector. Earlier in his career, he worked as a controller and auditor for six years. He is a member of the Massachusetts Bar, California Bar and the Ohio Society of Certified Public Accountants and is a Certified Management Accountant (CMA). Mr. Hardgrove has taught international taxation courses as an adjunct faculty member in the law school LLM programs at both the University of Washington and Golden Gate University. He is a frequent speaker and instructor on international taxation, migration, deferral and strategic planning matters. He has also written articles on international taxation, intangible property planning, global business issues, cross-border income taxation and planning for global expansion for the Journal of Accountancy, International Tax Review, CCH, the California Bar Journal and publications of the Canadian Tax Foundation. He is a contributor to PwC's Mastering the Intellectual Property Life Cycle, which discusses tax-efficient management of IP rights.
Elizabeth Herzberg is a Director with PricewaterhouseCoopers LLP in New York and has over 10 years’ experience in public accounting. She has significant experience with accounting for income taxes and regulatory reporting. Her clients include large financial institutions, consumer finance entities and multinational corporations both public and private. She has a broad technical background encompassing multiple industries including both domestic and inbound entity structures. Elizabeth Herzberg obtained her B.S.B.A from the University of Pittsburgh and is a licensed Certified Public Accountant.
Justin Hill is an associate with Baker & McKenzie in New York. His practice focuses on a wide range of federal income tax matters, including domestic and international tax issues related to mergers, acquisitions, and dispositions as well as equity and debt offerings. Justin began his career as a certified public accountant with KPMG LLP's state and local tax practice in 2004 and subsequently worked in the state and local tax practice at another international law firm before joining Baker & McKenzie in 2012. He received his J.D. magna cum laude from Fordham University School of Law and his B.B.A. from Baylor University.
Daniel Holzer is a manager in Ernst & Young LLP’s International Tax Services practice in New York. Daniel’s practice covers all aspects of international tax, including cross-border transactions; Subpart F, Section 956, foreign tax credit, tax-effective cash repatriation and supply chain planning; US trade or business issues and effectively connected income; tax treaty issues; and tax compliance. Daniel’s client portfolio includes media, consumer products, industrial products and pharmaceuticals companies. Prior to joining EY, Daniel worked as an associate at Simpson Thacher & Bartlett LLP in the Mergers & Acquisitions group in New York, advising both public and private clients on acquisitions, divestitures and spin-offs. Daniel received a B.A. with distinction in Economics from the University of Pennsylvania, a J.D., cum laude, from Fordham University School of Law, and an LL.M. in Taxation from New York University School of Law.
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.
Gwendolyn L. Hulsey is a member of the Tax Practice Group at Baker & McKenzie LLP in Houston. Prior to joining Baker & McKenzie, she served as Director of International Tax for El Paso Corporation in Houston, Texas. Ms. Hulsey practiced as a CPA in the tax practice of Arthur Andersen before joining El Paso. Ms. Hulsey represents and counsels multinational and U.S. clients in various tax and corporate transactions. She has a broad range of experience in all areas of federal income tax law, with particular focus on the energy industry, international tax planning and tax controversies. Ms. Hulsey received her B.B.A. in Accounting, magna cum laude, from the University of Houston and her J.D. from the South Texas College of Law.
Jessica Joy joined Duff & Phelps in 2012. Jessica is a managing director with considerable experience assisting multinational companies with their global transfer pricing needs – including documentation and planning studies, cost allocation analyses for the charge-out of centralized services, arrangements involving the use of intangible property, FIN48 reviews, audit defense, and financial modeling to examine the impact of intercompany pricing adjustments. Jessica serves clients in a variety of industries, with a particular focus on the financial services industry – including investment management, insurance and reinsurance, brokerage, commodities trading, and banking. Her experience ranges from global income and expense allocations for trading, investment banking and investment advisory services, to the pricing of intercompany loans and guarantees. Jessica also has experience with industrial and software companies. Jessica previously worked for Ceteris, and prior to that she was a Senior Manager in Deloitte Tax LLP’s global financial services transfer pricing group. Before joining Deloitte, Jessica was with Arthur Andersen, where she worked in their national transfer pricing headquarters and in the local Boston office. She has also worked at an economics consulting firm specializing in litigation support for the electricity industry. Jessica received an MBA from the University of Connecticut and a BA from Brown University.
Vinay Kapoor is a Principal in KPMG’s Economic and Valuation Services practice. 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. Transfer pricing planning and documentation with experience in a variety of industries including software, technology hardware, healthcare, industrial products, media, oilfield services and financial services. Focus on 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. Vinay earned his PhD and MA in economics (concentration in finance) from Cornell University and his BA in Economics from Cornell University.
Matvey Kats is a Senior Manager in the New York office of Deloitte Tax LLP’s International Tax Practice with over 6 years of experience in US International Tax. His practice focuses on developing optimal tax structures for proposed reorganizations, mergers, and acquisitions for US and foreign based multinational companies in corporate and private equity contexts. Matvey’s specific areas of focus include outbound and inbound transfers, taxation of passive income, foreign tax credit utilization, anti-conduit regulations, inversion transactions, treaty qualification, permanent establishment, and foreign investment in US real property. Matvey received his BBA in Accounting from CUNY Baruch College and his JD from Brooklyn Law School.
Ryan P. Keane is the founding member of Tax Resource Connection, LLC in the Town of Brookfield, Wisconsin. He advises U.S. foreign direct investment clients and large U.S. multinational corporations regarding international tax issues arising in their daily operations. He also represents clients before the IRS. During his 20-year career, Ryan has advised clients on a wide range of international tax matters including tax optimized inbound finance structures, withholding tax considerations, tax treaty benefit interpretations, and deemed international tax asset purchase elections. In addition, he has provided transfer pricing documentation services, U.S. tax credit planning for international taxes paid, and acquisition integration assistance. From 1996-1998, Ryan resided and served clients in Toronto, Ontario. Ryan earned a B.A. in Business Economics from Wheaton College in Illinois and a M.A.S. in Taxation from Northern Illinois University. He is a Certified Public Accountant, licensed to practice in Illinois and Wisconsin.
Christopher D. Kelley is a Partner at Ernst & Young LLP’s International Tax Services practice in Boston. Chris has worked in both the Detroit and Boston offices of Ernst & Young LLP. Chris has nineteen years of experience, fifteen of which were devoted entirely to international tax consulting. He has experience in international mergers, acquisitions and restructurings, as well as foreign tax credit, Subpart F and repatriation planning. Chris joined Ernst & Young LLP on May 2002.
Brad Kinder is a Manager in KPMG’s International Corporate Tax Services practice. He has been with KPMG since 2007. Brad advises clients on a variety of international tax matters including intangible property planning, supply chain and legal entity restructurings, cash redeployment and treaty issues. He also assists companies to calculate certain U.S. federal income tax attributes including earnings and profits, adjusted stock basis and foreign tax credits. Brad’s clients include multinational conglomerates and manufacturers, as well as pharmaceutical and biotech companies. Brad earned his BS in Accounting from Fordham University; his JD from Seton Hall Law School and his LLM from New York 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.
Alecia Kohorst is a Senior Manager in KPMG's Chicago International Tax practice and has over six years of experience in international tax. During her time with KPMG, Alecia has worked with a broad range of clients on US federal tax compliance, tax provisions, and cross-border transactions involving complex international tax issues. She earned my Bachelor of Science in Accountancy from the University of Illinois, and is a licensed CPA in the state of Illinois.
Chris Kotarba is an International Tax Senior Associate in DLA Piper’s Silicon Valley office. His practice consists primarily of international tax planning and transfer pricing. He has helped numerous high-technology, pharmaceutical, medical device and financial services companies expand globally in a tax-efficient manner. He also has extensive experience in IP migration and deferral structuring, supply chain optimization, withholding and consumption tax planning, inbound planning, cross-border M&A, post-acquisition integration and China tax. He has co-published Intersport and Taxpayer-Initiated Transfer Pricing Adjustments, 21 Transfer Pricing R. 88 (May 17, 2012) and a chapter in Taxation of International Partnerships (IBFD 2014). He received his J.D. from Columbia Law School and an LL.M. in Taxation from NYU School of Law. He is the President of the San Francisco Foreign Tax Club and an Executive Committee Member of the Bay Area Young Tax Lawyers.
Michelle Kwan is a manager in Ernst & Young LLP’s International Tax Services practice in Chicago. Michelle has more than four years of experience in international tax, which includes working on numerous compliance outsourcing projects for publically traded multinational companies and inbound companies. Michelle also works on earnings and profits pools/overall foreign loss studies, foreign tax credit calculations, and international modelling projects. She also has extensive experience auditing federal and international tax provisions for public companies and doing tax research projects. Michelle has a Bachelor of Science in Accountancy and a Master of Science in Accounting with a minor in Taxation from the University of Illinois. He is a certified public accountant licensed to practice in the state of Illinois.
Neal Kochman is a member of Chaplin & Drysdale in Washington, DC. Mr. Kochman's practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters. His experience covers a broad range of international, domestic, and state tax issues associated with transfer pricing, foreign tax credit planning, corporate restructurings, qualified settlement funds, and withholding and reporting. Mr. Kochman regularly advises clients on tax controversy matters, providing assistance during tax audits and representation in IRS Appeals proceedings, as well as in technical advice and ruling requests to the IRS National Office. He has represented U.S. multinational companies and U.S. subsidiaries of Belgian, German, Swedish and other foreign parents in advance pricing agreement and competent authority negotiations. Prior to joining Caplin & Drysdale, Mr. Kochman spent over 20 years performing quantitative and policy analyses for federal government agencies, which included: conducting econometric and statistical studies and developed cost allocation and pricing models, developing renewable energy research and development plans, and conducting defense acquisition policy studies. Mr. Kochman has written, been a guest lecturer at Georgetown University Law Center, and spoken at professional meetings on a variety of international and general tax topics, including foreign tax credits, transfer pricing, and the research credit. Mr. Kochman received his J.D. from Georgetown University Law Center, cum laude; Georgetown Law Journal; his M.I.E. from Cornell University and his B.S. from Cornell University.
Nelly Korsun joined Duff & Phelps as a director in the New York office. Nelly has over ten years of experience providing economic and business consulting services in the areas of transfer pricing and valuation. Throughout her career Nelly has advised clients on complex transfer pricing issues for global tax planning, documentation and supply chain restructuring initiatives. She has provided litigation and audit defense support in controversy matters, advised on intangible property valuation issues and cost-sharing arrangements, and performed transfer pricing reviews within M&A due diligence processes. Nelly also has considerable experience advising clients’ senior management teams on issues surrounding intercompany financing, including debt capacity, interest rates, risk transfers, guarantees and cash pooling arrangements. Nelly assists clients across a number of industries, most notably life sciences and medical devices, and financial services. Her client base also includes companies within specialty chemicals, automotive, consumer and industrial products, and telecommunications. Prior to joining Duff & Phelps, Nelly was a director at Ceteris, an independent transfer pricing and valuation firm. She also spent several years with BDO Seidman LLP and Charles River Associates. Nelly received her M.B.A., with honors, from the Johnson School at Cornell University, and a B.A. from Barnard College at Columbia University. She also holds a professional certificate in Credit Analysis and Credit Risk from the New York Institute of Finance and is progressing towards a certification in Business Valuation from American Society of Appraisers (ASA).
Jaclyn Obeso Kunkel is a Manager in KPMG’s Philadelphia International Tax practice. Jaclyn is a Manager in KPMG’s Philadelphia International Tax practice. She has significant experience advising multinational companies on U.S. tax considerations. Jaclyn joined KPMG in July 2010 after working as a tax attorney for two years for a private client law firm in Connecticut. Before going to law school, she worked for another Big 4 public accounting firm’s Miami office as a transfer pricing associate. Jaclyn has served as project manager on several large value chain management projects. She has extensive experience with a wide range of complex tax matters relating to her clients’ businesses. For example, Jaclyn has: Advised numerous U.S. multi-national corporations on exposure to U.S. and non-U.S. taxation stemming from their business activities outside the U.S., and assisted in providing recommendations for various tax-efficient structures and strategies with respect to outbound transfers of property, subpart F income, foreign tax credit optimization, and international restructuring. Advised numerous non-U.S. corporations on minimizing exposure to U.S. taxation as a result of their activities in the U.S., and recommended various tax-efficient structures and strategies with respect to U.S. withholding tax, effectively connected income, and the availability of treaty benefits. Jaclyn earned her BA from Duke University and her JD from Fordham University School of Law. She is admitted to the Bar in New York and Connecticut.
Frank Landreneau is a CPA and Director of International Tax Services at Pannell Kerr Forster of Texas and has extensive experience providing domestic and international tax consulting and compliance services to private as well as public entities located within Texas and Louisiana. He has consulted with companies doing business in the banking, construction, technology, oil field services, and manufacturing/distribution industries. His experience also includes assisting clients operating in various foreign tax jurisdictions with a variety of international tax issues, such as transfer pricing, global tax minimization, and international organizational structuring. Additionally, he has consulted with companies on a number of complex tax issues related to acquiring and divesting of subsidiaries in order to realign their businesses. During his years in public accounting, he has assisted clients with accounting method changes, flow-through tax planning, IC DISCs, and FAS 109 deferred tax analyses, as well as uniform capitalization issues, IRS examinations, and other tax planning techniques. While at PKF Texas, Frank has become the outsource solution for international tax services for many offices within PKF North America. Frank’s expertise also includes repatriation planning involving foreign holding company structures. Frank has also worked with a number of foreign companies in structuring their U.S. business operations. In particular, Frank serves a number of clients based in Europe, including those in the United Kingdom, Germany, Italy, and the Netherlands. Frank also chairs quarterly international conference calls for the Leading Edge Alliance. Frank is a Certified Public Accountant in Texas. He received his BBA in Accounting from the Louisiana State University and his MS in Accounting and Taxation from the University of Houston.
Rodney J. Lawrence is the principal-in-charge of the Midwest International Corporate Services practice. He has practiced in this field with KPMG globally since 1987 and is currently a member of the firm’s Global International Corporate Tax Practice. Rodney has represented clients before the Internal Revenue Service regarding examinations and ruling requests. He has assisted clients with effective global tax rate planning, including such matters as foreign tax credit planning, financing, contract manufacturing, transfer pricing and efficient repatriation. Rodney has advised a wide variety of US publicly listed multinationals on matters from IPOs to mergers, acquisitions and divestitures and restructurings. Recent projects include the successful migration of intangibles from the US; implementation of a supply chain redesign including contract manufacturing, planning for repatriation and efficient foreign tax credit utilization and refinancing of foreign operations. Rodney has also advised a range of foreign investors and multinationals. Recent projects include the efficient acquisition of a US group, a successful IPO of a US multinational on a foreign exchange, the restructuring of a group to move foreign subsidiaries out from under US ownership, and the efficient repatriation of earnings as well as assisting numerous foreign governments and investment funds. Rodney is a frequent presenter on international tax planning matters and has authored numerous articles of interest.
Josh Leclair is a member of KPMG’s Boston’s international tax practice, having joined the firm in October 2014. Josh has a wide range of international tax experience including, primarily, corporate outbound planning and compliance, but also corporate inbound planning and compliance and non-US planning. Josh has more than 11 years of experience advising a broad range of clients on a broad range of international tax issues. These clients include small, privately held real estate investment operations and large multinational corporations and the issues include Subpart F, foreign tax credits, withholding, permanent establishment, effectively connected income, cross border acquisitions and divestitures, tax efficient repatriation, internal restructurings, planning related to intellectual property, and planning related to sourcing structures. Josh also has past experience in other “Big Four” firms. He is an expert in Subpart F (including § 956), foreign tax credits, effectively connected income, permanent establishments, various structuring, and transfer pricing. Joel earned his J.D. form William Mitchell College of Law in St. Paul, MN and his LL.M.
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.
Erin Lien is a member of Ernst & Young LLP’s International Tax Services group in New York. Erin’s primary areas of concentration include international tax advisory services, including tax efficient supply chain management, cross-border restructuring transactions, Subpart F considerations and other issues related thereto. Her practice includes both inbound and outbound US tax matters. Before joining Ernst & Young LLP, Erin was an associate with Baker & McKenzie LLP’s New York office. At Baker & McKenzie, Erin’s practice covered a wide range of tax issues, including U.S. federal, state and local, transfer pricing, and international tax practice, before focusing her practice on international tax planning. While at Baker & McKenzie LLP, Erin served as Secretary of the New York City Bar’s Committee on Pro Bono and Legal Services. Erin holds B.A.s in Economics and Spanish from the University of California, Los Angeles (Provost’s honors), a J.D. from Georgetown University Law School, and an LL.M. in Taxation from New York University School of Law. Erin also holds a Certificate in Spanish Studies from the Universidad de Salamanca. While at Georgetown, Erin was a member of the Institute for Public Representation, Communications Division, an editor of the Georgetown Law Weekly and a Georgetown Student Ambassador. Prior to entering the field of tax law, Erin served as a law clerk for the Office of the District Attorney of Santa Clara County, Juvenile Dependency Unit, and as an intern to the White House. Erin is licensed to practice law in New York and in California. She has published several articles addressing a range of tax issues. She is a member of the American Bar Association, as well as a member of Mensa.
Jason LaRosa is a Director at KPMG LLP in Houston. Jason works with many multinational clients, primarily in the oil field services, offshore drilling and manufacturing industries, on international tax-related projects. He consults on cross-border reorganizations, acquisitions, dispositions and debt-financing, specializing in structuring transactions to minimize worldwide taxes. Jason provides tax advice on tax efficient business structures for U.S. based businesses expanding into global markets and foreign-based businesses expanding into the U.S. He assists with the international aspects of U.S. tax and financial reporting, earnings and profits calculations, foreign tax credit calculations, U.S. GAAP and IFRS, and other compliance projects. Jason is a CPA and earned his Master of Laws in Taxation from the University of Missouri and his JD from Duquesne Law School and his BS in Accounting from St. Vincent College.
Jeffrey A. Levenstam is an international tax services partner at Ernst & Young 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.
Mike Lutz is a partner at Ernst & Young LLP in Boston. Mike has more than 14 years of experience providing international tax services to US and non-US based multi-national clients and has extensive experience in US international tax matters related to: the development of tax planning strategies with respect to cross-border reorganizations and acquisition planning; the design and implementation of intellectual property centralization; the design and implementation of tax-efficient financing structures as they relate to both internal reorganizations and third party acquisitions; the tax consequences of existing and changing treasury structures, including the repatriation of foreign earnings; general subpart F, foreign tax credit and foreign source income matters. Mike earned his BA in Economics from Boston College and his J.D. from Loyola University Chicago School of Law. Mike is admitted to the bar in Massachusetts and Illinois.
Kathy MacDonald is an executive director in the Chicago office of Ernst & Young LLP and a member of EY’s International Tax Quantitative Services line. Kathy has 14 years of public accounting experience providing international tax services for publicly owned multinational companies. She worked at EY from 1998 to 2006 and recently rejoined the Chicago practice. Kathy has extensive experience in the area of international compliance. Kathy’s recent projects have included a combination of US international tax compliance, research and planning engagements. One of these projects involved the analysis of corporate structures and transactions to determine US filing requirements for a client that files over 300 returns for operations in 50 countries. On this project, Kathy drove the process for collecting and analyzing local country data to support the US international compliance and tax provision processes. On another project, Kathy successfully teamed with other service lines to develop tools that streamlined and automated various manual processes. Kathy has helped clients with the implementation of OneSource Income Tax and has managed all international aspects of compliance engagements. She earned her Bachelor of Science in Finance from Northern Illinois University and her Master of Accounting Science, Specialization in Taxation from University of Illinois – Urbana/Champaign.
Phyllis Marcus is a Director International Tax Services at PricewaterhouseCoopers LLP Washington National Tax Services office. Before joining PWC, Ms. Marcus spent 35 years working in the international tax area at IRS. Beginning in 1986, Ms. Marcus was a Branch Chief in the Office of the Associate Chief Counsel (INTL) where areas under her jurisdiction included subpart F, PFIC, CFC reporting, conduit transactions, taxation of expatriates and nonresident withholding. During her career at IRS, she saw many international tax issues, participated in the litigation of significant foreign tax credit and subpart F issues and was involved in the drafting of significant tax guidance, especially in the subpart F area of the law. Phyllis has a BSBA from Washington University in St. Louis, a JD from Cleveland State University, and an LLM in Taxation from Georgetown University. She is a member of the Ohio and District of Columbia Bar Associations.
Michael J. Masciangelo is a partner in and member of Ernst & Young LLP’s International 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.
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.
Neelu Mehrotra is a member of Ernst & Young LLP’s National International Tax Services Quantitative practice. She is based in Providence, Rhode Island. Neelu has more than 15 years of experience providing quantitative international tax services, including international compliance, earnings and profit studies, and calculation of foreign tax credits. She has also managed the international compliance process at large private clients before re-entering public accounting. Neelu is knowledgeable about tax software systems in regard to international tax forms and the provision process, and she has developed tools, such as a data gathering tool that links systems to process, to streamline international compliance. She has worked with family offices and tax exempt organizations as well with their foreign reporting requirements.Neelu has a Bachelor of Arts in Economics and Math from Connecticut College and a Master of Science in Public Accounting from the University of Hartford. She also has a Master of Science in Taxation from Bryant University. Neelu is an Enrolled Agent.
Sean K. McFerson has more than 16 years of experience in public accounting and is currently a partner at Windes LLP in the firm’s Tax and Accounting Services practice. He specializes in domestic and international taxation issues of multi-national companies (both public and private), and start-up companies, including domestic and international restructuring, consultation on year-end and quarterly income tax provisions, tax-efficient integration of acquired targets, developingand implementing intellectual property-migration strategies, and formation of international entrepreneur structures. Sean’s expertise extends to consultation and preparation of various federal and international tax reports, such as net operating loss studies, accounting method changes, and miscellaneous foreign reporting. Sean serves a wide variety of clients in the technology, manufacturing, distribution, services, and high-net-worth individuals. Sean’s experience includes working abroad, in London, UK, where he worked at the United States Tax Desk for PricewaterhouseCoopers LLP. Sean has a Bachelor of Science in Accounting from Loyola Marymount University and a Master of Business Taxation from University of Southern California. He is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Robert J. Misey, Jr. is a shareholder at Reinhart Boerner Van Deuren in the firm's Tax and Business Law Practices and Chair of the International Practice. He concentrates his practice in the areas of international taxation and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment. Mr. Misey's previous legal experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney and as a trial attorney. Mr. Misey regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs. His speaking engagements have taken him to numerous states and foreign countries. Mr. Misey also teaches international taxation at the Master of Tax. Mr. Misey received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University.
Evgeniya Mudrich is manager in KPMG’s New York Financial Services Tax practice with over 8 years of experience serving financial services clients, primarily in the banking industry. Evgeniya has worked for KPMG in the Financial Services group. She has provided services for various domestic and foreign banking and other financial services related clients. Evgeniya regularly assists clients with federal, state and local tax compliance (federal, state and local tax returns and estimated tax calculations) and tax provision preparation and/or review, IRS and State Audits. Some examples of her experience include: Managing the overall tax compliance process for clients, including quarterly estimated tax payments, annual tax returns, and other tax filing obligations; Assisting clients with federal and state audits and prepare correspondence to the tax jurisdiction in response to the federal and state notices; Preparation and/or review of ASC 740 tax provision calculations for domestic and foreign based financial services companies. Reviewing Fin 48 tax exposure calculations and related accounting for such items; Conducted research on specific tax and accounting issues and prepared memoranda outlining issue, analysis and conclusion. Evgeniya has a B.A. in Accounting from Baruch College, an M.A. in Economics from South University in Russia and is a CPA in New York.
Reza Nader is a member of Baker & McKenzie’s North 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.
Zey Nasser is a member of Ernst & Young LLP’s International Tax Services practice and is based in San Francisco. Previously, Zey was a tax associate at Clifford Chance US LLP. Zey has more than 16 years of experience providing tax structuring and planning advice for a wide variety of domestic and multi-national clients. Zey has experience in subpart F and foreign tax credit planning, acquisitions and dispositions, spin-offs and foreign in-bound and outbound transactions. Zey also has experience in hybrid and other cross-border financings and in representing issuers and underwriters in US and Euromarket offerings. She has worked on a wide variety of international financial and business transactions, including investment funds, carried interest and management co-investment arrangements, private equity investments and joint ventures. Zey is a tax attorney licensed to practice in California, New York and Washington, DC. She received an LL.M in taxation, on full scholarship, from Georgetown University Law Center.
Maruti Narayan is Of Counsel in the New York office of DLA Piper LLP. She advises U.S.-and foreign-based multinationals on a broad range of international tax matters, including supply chain structuring, IP migration, U.S. income tax treaties, and cross-border mergers and acquisitions. Prior to joining DLA Piper, Maruti was a Senior Manager in the Washington National Tax office of Deloitte Tax LLP, in the International Tax group. While at Deloitte, Maruti co-authored the BNA Tax Management Portfolio titled: “Outbound Planning for U.S. Multinational Corporations”. Prior to joining Deloitte, Maruti was a Tax Associate with Shearman & Sterling LLP’s Washington DC office and Akin Gump LLP’s New York’s office. Maruti received her J.D. from University of Virginia School of Law in 2004, where she was a Managing Editor of the Virginia Tax Review. She received her B.A., with distinction, in Political Science, from Yale University in 2001.
William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments. He is also a member of the firm’s Tax Litigation and Controversy Group. He is a Certified Specialist in Taxation Law. In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriations of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court. Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law. He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch. He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute. In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation.
Ken O’Hara has been with KPMG for 15 years in Boston. Ken has worked on a wide range of engagements, including documentation, planning, assisting clients with responses to IDRs and IRS audits, APAs, and provision/FIN 48 reviews. During his tenure with the firm, Ken has gained experience with most types of intercompany transactions, including tangible, intangible, service and financial (loan/guarantee) transactions. He has also assisted clients with respect to the adoption of the temporary services regulations, and more recently, addressed questions regarding the temporary cost sharing regulations. Ken has assisted multiple clients (typically US manufacturing subsidiaries with foreign parents) in responding to IDRs. He has prepared transfer pricing documentation and planning work for clients in wide range of industries, including pharmaceutical, industrial (manufacturing), consulting, electronics, entertainment, food and beverage, publishing, and eyewear.
Klaus Oehring is the international transfer pricing specialist. 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 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.
Melinda R. Phelan is a member of the management committee for Baker & McKenzie's North America Tax Group. She is a regular presenter on tax issues for a broad range of conferences, including those organized by the Tax Executive Institute and Baker & McKenzie. She is a member of the Tax Section of the American Bar Association, as well as the State Bar of Texas and the Dallas Bar Association. Ms. Phelan assists clients — including multinational firms — with transfer pricing, as well as domestic and international tax planning. She has been involved in numerous global transfer pricing projects and advance pricing agreements. She also handles the legal aspects of designing and implementing structures to minimize global taxation, and is experienced in domestic and international M&A transactions. Ms. Phelan has worked on cases involving tax controversy, particularly at the audit, appeals and litigation levels. Ms. Phelan earned her J.D. (magna cum laude) from Tulane Law School and her B.A. (Honors) from University of the South.
Ken Picciano is a partner at KPMG LLP and has more than 20 years experience advising large and middle market multinational companies on a variety of international tax matters with a focus on cross-border mergers and acquisitions. Mr. Picciano works closely with KPMG’s mergers and acquisitions practice and foreign offices on a variety of cross-border acquisitions, mergers and restructuring involving both U.S. and foreign-owned multinational companies. Mr. Picciano has extensive experience dealing with foreign tax credit planning, repatriation planning, subpart F issues, international expansion and post-acquisition structuring. Mr. Picciano previously did rotation in KPMG’s Washington National Tax Practice, where he worked in the international corporate tax group. Mr. Picciano has co-authored “The Euro is Coming: A Look at Some of the Complex U.S. Tax Issues,” published in the Journal of International Taxation, March, 1998; Co-authored “Final Regs. Clarify Cost Sharing of R&D Expenditures,” published in The Tax Advisor, January, 1997. He is a frequent presenter at various international tax seminars in the Philadelphia region. Mr. Picciano is a graduate of the Philadelphia branch of Leadership, Inc., an organization that provides leadership training to residents of the Greater Philadelphia area Chapter. He received his M.S. in Taxation form Villanova University and his BA in Economics from Rutgers University. Mr. Picciano is a Certified Public Accountant.
Sam Pollack received his J.D. from the University of Illinois in 2013. Since his graduation, he has worked as an associate at Baker & McKenzie’s Global Tax Practice Group. He provides domestic and international tax planning advice for corporations and pass-through entities. Mr. Pollack advices US, non-US and multinational clients on federal income tax matters related to mergers and acquisitions, joint ventures, private equity funds and real estate transactions.
James Prettyman is a partner in the Mergers and Acquisitions Group in PricewaterhouseCooper's Houston office. Previously, James was an M&A partner in PwC's Washington National Tax Services office. He specializes in corporate transactions and consolidated returns and cross border restructuring. James has over 20 years of experience in public accounting. James provides consulting services to the clients on numerous acquisitions, dispositions, restructurings and tax planning projects. These projects include optimizing the tax position of the clients on acquisitions and dispositions, tax basis and earnings and profits studies, section 382 analyses, and private letter ruling requests. He also has experience in cross-border restructurings, restructuring of consolidated groups in anticipation of REIT IPOs, internal spin offs, and several acquisition and disposition related consulting projects. In addition to his client responsibilities, Mr. Prettyman has participated in a number of panels for TEI, ALI/ABA and other organizations. James received his Bachelors of Business Administration in accounting and a Masters in Professional Accounting with an emphasis in tax from the University of Texas at Austin. He is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.
Peni Saccoh is a senior manager in Ernst & Young’s International Tax Services practice and is based in Boston. Peni joined Ernst & Young in 2003, and over the course of her career has worked extensively with various US multinational and inbound companies in the technology, life sciences, and retail industries. Peni specializes in reviewing international tax provisions for large companies with complex global structures, and manages several international tax compliance projects for companies with foreign corporations, partnerships and disregarded entities. Peni also specializes in providing international tax planning services for clients with repatriation, restructuring, rationalization and refinancing needs. She holds a B.B.A. in International Business from Howard University, a J.D., MBA, and MS in Accounting from Northeastern University, and an LLM in Taxation from Boston University. She is both a Certified Public Accountant and a licensed attorney.
Christopher Sandry is a member of Ernst & Young LLP’s International Tax Services practice in Boston. He started his career at Ernst & Young LLP in Sydney, Australia in 2006 and transferred to the Ernst & Young LLP Boston office in 2010. Christopher has ten years of Australian and U.S. International tax consulting and compliance experience. He has experience in international mergers and acquisitions, U.S. foreign Tax credit planning, Subpart F planning, repatriation planning, international tax provisions and international compliance and reporting. Christopher has serviced the private equity, real estate, software and technology industries. Christopher holds a Bachelor of Laws and Bachelor of Accounting from Macquarie University, Australia, and is a member of the Institute of Chartered Accountants Australia, a solicitor of the Supreme Court of New South Wales and an IRS Enrolled Agent.
James K. Sams is a Principal at KPMG LLP in McLean, VA. James provides a high level technical assistance and consulting services to clients on a wide range of inbound and outbound U.S. international tax issues, serving KPMG business offices and clients across broad range of industries and geographies. Areas of U.S. tax technical expertise and experience include intangibles transfers, cross-border acquisitions and restructurings, foreign tax credit limitation, application of anti-deferral regimes, U.S. trade or business and permanent establishment exposures for foreign persons’ activities in the U.S., and application of U.S. income tax treaties. Significant transactional experience also with U.K.- and U.S.- based private equity funds with U.S. investors and/or U.S. investments. Represent clients before the Office of Assistant Commissioner (International) and the Office of Chief Counsel on various matters, including commentary on regulations, issues under examination, transactions for which private letter rulings are sought, and transactions for competent authority consideration.
Peter J. Scalise serves as the Federal Tax Credits & Incentives Practice Leader for the Americas at Prager Metis CPAs, LLC a member of The Prager Metis International Group. Peter is a highly distinguished BIG 4 Alumni Tax Practice Leader and has over twenty years of progressive CPA Firm experience developing, managing and leading multi-million dollar tax advisory practices on a regional, national, and global level. Peter is a highly acclaimed thought leader in the fields of accounting and taxation with deep subject matter expertise in connection to designing, implementing and defending sustainable methodologies for specialty tax incentives including, but not limited to, research tax incentives; orphan drug credits; energy tax incentives; movie production tax incentives; accounting methods and periods; and comprehensive fixed asset analysis incorporating principles of construction tax planning, cost segregation analysis and tangible property regulations compliance. Peter serves on both the Board of Directors and Board of Editors for The American Society of Tax Professionals (“ASTP”) and is the Founding President and Chairman of The Northeastern Region Tax Roundtable, an operating division of ASTP.
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 (1998), a JD from the University of Chicago Law School (2002), and an LLM in Taxation from the Northwestern University School of Law (2008).
Matt Schimka is a Senior Manager in KPMG’s Chicago International Tax practice. He has over five years of experience in international tax planning and structuring. Matt has worked with a broad range of U.S. multinational and foreign-owned clients, and has extensive experience with a wide range of complex international tax due diligence and tax structuring matters relating to his clients’ businesses.
Caren S. Shein is a Managing Director at KPMG LLP’s National Tax Office in Washington, DC. Ms. Shein advises clients on outbound and inbound international tax planning and compliance issues, including foreign tax credit, subpart F, expense allocation, and permanent establishment. Her particular area of expertise is the foreign tax credit, and she regularly writes, speaks and teaches in this area. Caren is the author or co-author of numerous articles, including“Uncovering the Covered Asset Acquisition Rules,” The Tax Executive (Sept.-Oct. 2010), “Emergency Economic Stabilization Act of 2008 – Throwing a Rope to the Ailing Financial Industry Tightens the Noose on Big Oil,” Tax Management International Journal (February 2009), “Temporary Regulations Deny Foreign Tax Credits for Amounts Paid Pursuant to “Structured Passive Investment Arrangements”, Tax Management International Journal (October 2008), “New Temporary Regulations Under Section 905(c): A Big Improvement but Puzzling Issues Still Remain,” Tax Management Journal (May 2008), “The IRS Proposes a New Approach to Determine the Technical Taxpayer – Will it Work?,” Journal of Taxation of Global Transactions (Fall 2006), “Section 905(c) – The Missing Piece of the Foreign Tax Credit Puzzle”, Tax Management International Journal (January 2002), and “A Fresh View of Overall Foreign Losses and Consolidated Returns”, Tax Management International Journal (May 1999). Prior to joining KPMG, Ms. Shein was an attorney advisor at the Internal Revenue Service, Office of Associate Chief Counsel (International). There she worked on rulings, regulations and litigation, primarily relating to foreign tax credits. Ms. Shein began her career as a law clerk to the Honorable B. John Williams, Jr., of the United States Tax Court.
Jessica A. Silbering-Meyer is a member of Ernst & Young LLP’s International 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 Media & Entertainment, Telecommunications, and Consumer Products. 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.
Moshe Spinowitz represents clients on a range of tax matters related to corporate transactions, including public and private company mergers and acquisitions, with a particular emphasis on international tax matters, cross-border acquisitions, and post-acquisition integration and restructuring transactions. In addition, Mr. Spinowitz advises clients on a range of tax controversy matters during all phases of IRS audits and appeals. Mr. Spinowitz’s experience includes advising a multinational pharmaceutical company in connection with the integration and restructuring of its operations following a large cross-border acquisition, advising pharmaceutical and technology companies in connection with the structuring of their intellectual property holdings, and successfully representing several multinational corporations before IRS appeals in connection with intercompany financing transactions. Prior to joining Skadden, Mr. Spinowitz served as a law clerk to Judge Michael Boudin on the United States Court of Appeals for the First Circuit, and Justice Antonin Scalia on the United States Supreme Court.
Tanu Srinivasan is a Senior Manager in Ernst & Young’s International Tax Services group in Boston. Tanu has over seven years of experience in transfer pricing, including documentation, IP and supply chain planning, and controversy. Tanu has performed transfer pricing analyses for large multinational companies in a variety of industries, including life sciences, technology, biotechnology, software, and luxury retail. Tanu’s experience includes: transfer pricing engagements related to documentation, IP, restructuring & supply chain, due diligence, tax planning, and controversy. Tanu holds a BS in Economics from the University of Pennsylvania, a JD from Northwestern University School of Law, and an MBA from Northwestern University’s Kellogg School of Management. She is admitted to the bar in Illinois. Tanu joined EY in August 2005 in the Firm’s New York transfer pricing practice. Prior to re-joining EY in 2012, Tanu practiced law at a large law firm in Chicago.
Paul Tadros is President at DSN Consultants based in Atlanta, GA. Paul 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.
Jay Tata leads KPMG’s International Corporate Services tax practice in New England. He joined KPMG in 1999 and was promoted to partner in 2007. Jay has over 15 years of public accounting tax experience and over the past 10 years he has focused on providing domestic and international tax structuring advice and tax due diligence assistance in acquisition transactions. Jay experience spans more than 75 buy side transactions, both domestically and internationally, ranging in size from $10 million up to several billion dollars. Participation in these transactions included coordinating and leading tax due diligence investigations, providing technical tax and transaction structuring guidance and reviewing purchase and sale agreements. Jay specializes in international corporate taxation and has a strong background in corporate and partnership taxation, mergers and acquisitions, and accounting for income taxes. Jay’s experience includes assisting multinational corporations with global tax planning, restructuring projects, foreign tax credit planning, and foreign cash repatriation planning. Jay received his BBA in Accounting, University of Massachusetts in Amherst and his MST from Golden Gate University in San Francisco. Jay is a Certified Public Accountant in Massachusetts and California and a Member of AICPA and Massachusetts Society of CPAs.
Gabriel Taubenfeld is a Senior Manager in Ernst & Young LLP’sInternational Tax Services practice. He advises multinational corporations and private equity investors on a variety of international tax matters related to cross-border transactions and general international tax planning. Gabe has advised on numerous cross-border M&A transactions, financing and reorganizations, ranging in value between $10m and $23b across a broad range of industries. In this regard he is experienced in transaction structuring, tax modeling, due diligence and pre and post-transaction restructuring. Gabe also regularly assists both US and foreign multinational clients with all aspects of US international tax planning and compliance. In particular, he has assisted clients with foreign tax credit planning, tax-effective cash repatriation planning, Subpart F planning, tax treaty issues, US trade or business issues and effectively connected income. Gabe received a B.A. in Accounting from the City University of New York at Queens College, a J.D. from Fordham University School of Law and an LL.M. in Taxation from New York University School of Law. He is a member of the Tax Section of the American Bar Association and is a certified public accountant in New York.
Brian Trauman is a partner and tax lawyer at KPMG LLP whose practice is focused primarily on federal and international tax controversies. In this context, Brian has directed and managed enterprises’ transfer pricing strategies, compliance and controversies through coordination of parent companies and their worldwide affiliates in a variety of industries and functions. His experience with controversies includes audits, administrative appeals and litigation in subject matters ranging from subpart F to leasing to promoter audits to transfer pricing. In addition, he has successfully lobbied Congress, the IRS and the US Treasury for changes to income tax laws and guidance. Brian has particularly significant experience in advising on supply chain organization and tax efficiency, as well as on direct and indirect tax and transfer pricing consequences of various functions including manufacturing, distribution, logistics and services. Brian has worked with revenue authorities and industry participants in North and South America, Europe, Asia, Africa and Australia to obtain successful resolution of controversies, including mutual agreement procedures, advance pricing agreements and rulings. Brian joined KPMG after working for a major law firm in Washington, DC. Previously, he served as Law Clerk for The Honorable L. Paige Marvel, United States Tax Court, Washington, DC. Brian was recently recognized in International Tax Review, World Tax 2009 by a tax director as having "excellent judgment and knowledge in transfer pricing."
Eric Tyan is an international tax senior manager at KPMG LLP. Eric works with multinational clients of various industries on US international tax‑related issues. He provides clients with US and foreign inbound investment consulting and compliance services. Eric consults on cross border reorganizations with respect to company structure realignment, cash repatriation, foreign source income planning, etc. In addition, Eric assists clients with managing tax attributes such as earnings and profits computations, foreign tax credit computations, subpart F income computations, etc. Further, he performs tax provision review in accordance with US GAAP and effective tax rate analysis.
Miquel (Mike) Valdes specializes in Latin America and Caribbean transfer pricing and business matters with special emphasis on Brazilian transactions. Before July 1, 2002, Mr. Valdes was the National Director of the Latin American Business Center, coordinating Ernst & Young's expansive Latin America resources of the Foreign desk program. He has over 25 years of international tax consulting experience. Prior to joining Ernst & Young, Miguel worked for a major law firm, where he specialized in Latin America tax planning, and was a partner at another Big 5 accounting firm. As Director of Taxes for a multinational pharmaceutical company, he spearheaded projects such as the company's transfer pricing litigation, §936 operations in Puerto Rico and investments in Latin America. Miguel is a frequent speaker at the American Conference Institute, Tax Executive Institute and other organizations. Lawyer and certified public accountant, Mr. Valdes received his B.S. from Loyola University and his M.S. and J.D. from DePaul University and DePaul University Law School respectively. He is a member of the Illinois CPA Society, American Institute of CPA's, the American Bar Association, Florida Bar Association and other professional organizations.
Nelson Valentine is currently a senior manager at Deloitte Tax LLP in our New York International Tax Services Group. Nelson has over 10 years of experience in public accounting and has served a number of clients in a tax consulting, compliance and M&A advisory role in various industries including private equity, real estate, financial services, oil & gas and energy, healthcare, technology and telecommunications. He has extensive experience working with companies to identify and implement U.S., international and local tax strategies associated with their specific business challenges including various multinational restructuring transactions and cross border real estate investments for Real Estate Investment Trusts (REITS) and Private Equity Funds. Respective clients served include The Blackstone Group, Och Ziff Capital Management, American Express, Vornado, Goldman Sachs, American Realty Capital, Bessemer Venture Partners, Hudson’s Bay Company, Eaton Corporation, Manulife Financial, KSL Capital Partners, Prologis, Immucor, Inc., Atlantic Tele-Network, Inc., Kimco Realty, Scientific Games Corporation, DLJ Real Estate Capital Partners and Black Creek Capital. He received his B.Acc. and M.Acc from the University of Mississippi and is a Certified Public Accountant in New York and Georgia.
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.
Steve Weerts is a partner in the Tax practice of White & Case 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 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 a principal in KPMG’s Economic and Valuation Services practice. He serves as the National Leader for Transfer Pricing Dispute Resolution (TPDR) and the Deputy Head of Global TPDR. Steve splits his time between the firm’s Silicon Valley and McLean Offices. In the nearly two decades prior to joining KPMG, Steve led the APA practice at two other Big Four Firms and was a partner with a global law firm. Before that, Steve served as a senior attorney with the Advance Pricing Agreement Program in the U.S. Internal Revenue Service Office of Associate Chief Counsel (International). Steve has over 30 years of tax experience and 23 years of client and government experience in transfer pricing across all industries and types of transfer pricing issues. Steve’s client service in transfer pricing controversy includes examination, appeals, alternative dispute resolutions, advance pricing agreement (APAs), mutual agreement procedures (MAP) and customs agreements. He is one of the most experienced transfer pricing negotiators anywhere, with a combined APA and MAP experience of more than 150 cases. He represents a number of Fortune 500 clients in transfer pricing disputes. Steve teaches transfer pricing at Georgetown University Law Center, the University of Florida School of Law, and New York University School of Law. He has also taught transfer pricing and transfer pricing controversy at the IRS, U.S. Customs and several other tax authorities. Steve recently published the fourth edition of his leading U.S. transfer pricing treatise (1,100 pages) and has written more than 100 articles on transfer pricing topics. Steve speaks globally with governments and taxpayers on transfer pricing and dispute resolution topics. Steve has served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of New York University School of Law’s International Tax Program and BNA Tax Management (Transfer Pricing). Steve earned his B.B.A. (Accounting) from the University of Notre Dame; his J.D. from the University of Texas School of Law, and his LL.M. from the New York University School of Law.
Katherine (Kathy) Wu is an Executive Director with Ernst & Young LLP’s Tax Services practice in Iselin, New Jersey. Kathy focuses on tax accounting and international tax assisting US multi-national corporations with foreign tax credit planning, earnings and profits studies, tax compliance, foreign branch planning, tax provision process improvement, income tax balance sheet validation, and FIN 48 analysis. Kathy has assisted many large U.S. multinational companies with their yearend tax provisions. Kathy teaches foreign tax credit and tax accounting subjects at internal EY training and is an adjunct professional at Monroe College. Katherine received her B.A. degree from Washington University in St. Louis and her M.S. degree in Taxation from Seton Hall University. Katherine is a Certified Public Accountant licensed in New Jersey and New York. Kathy is a member of the American Institute of Certified Public Accountants and the New Jersey Institute of Certified Public Accountants.
Raymond Wyeth is a Partner at Grant Thornton in New York. He orchestrates the execution of projects blending a practical technician approach along with his extensive ASC 740, Accounting for Income Taxes expertise. Raymond’s approach to every project is to simplify the technical, ease the burden, and execute with finesse. Raymond has over 15 years of tax experience with commercial and service companies. His technical expertise includes Corporate, Partnership and S-Corporation taxation. as well as extensive experience with ASC 740 – Accounting for Income Taxes and Accounting for Uncertainty in Income Taxes. Raymond’s robust experience includes both domestic and foreign operations, publicly-traded as well as privately-held companies. Raymond actively participates in the Financial Executives Institute (“FEI”), New York Chapter. As the Sponsor contact, Raymond works with FEI membership and Grant Thronton to bridge the need for industry specific thought-leadership. Raymond is working extensively with professional service, manufacturing and cloud- based entities. These dynamic companies range from $8 billion in sales to start-up companies. Raymond’s extensive experience and education allow him to assist at all cycles of an entity’s life and deliver his technical expertise ensuring the Grant Thornton experience. Raymond serves as the lead on his assignments, assisting Companies with the complexity inherent in ASC 740, Mergers and Acquisitions, Reorganizations, Tax optimization strategies for flow-through entities, in addition to foreign tax analysis. Orchestrating these assignments requires Raymond to coordinate with Grant Thornton International Affiliates, giving Raymond a worldwide network within Grant Thornton. He received his B.S. from West Chester University in Accounting and his Masters of Taxation from Villanova University.
Raymond P. Wynman is the Director of Global Tax Management’s International Tax practice. He focuses on providing clients international tax quantitative and compliance services as well as international tax planning. Raymond joined GTM in 2016 with over 20 years of international tax experience. His leadership and domain expertise in international tax helps clients navigate the complexities of international tax compliance and provides international tax planning dictated by business operations. He services clients in the life sciences, manufacturing, consumer products, and service industries. Prior to joining GTM, Raymond was an international tax partner with Ernst & Young. In this role, he advised multinational clients on effective US and worldwide income tax planning for global tax minimization, focusing on areas such as foreign holding company and supply chain/transfer pricing tructures, foreign cash repatriation, post-merger integration of newly acquired entities, and maintaining deferral of foreign earnings from US taxation. He also practiced in the international tax quantitative and compliance area such as foreign tax credit maximization, overall foreign loss planning, post-foreign holding company structure maintenance, fair market value of apportioning interest expense, foreign earnings and profit studies, and international tax compliance topics. Additionally, he helped companies in the international tax accounting area.
David Young joined KPMG in 2011 as a Senior Manager in the International Corporate Services tax practice in New England. Prior to joining KPMG, David was Senior Tax Counsel at Raytheon Company where he led teams responsible for international tax matters and tax quality assurance. David’s prior experience includes, planning and structuring transactions for public and privately held companies as a senior associate in the Tax Practice of Pepper Hamilton LLP and as a senior manager in the Transaction Advisory Services Tax Practice of Ernst & Young LLP. David specializes in international corporate taxation and has over 15 years of experience advising clients on corporate taxation, mergers and acquisitions, and taxation of affiliated and related groups. David’s experience includes assisting multinational corporations with global tax planning, tax efficient global supply chain restructuring, tax efficient repatriation of foreign cash, and global tax controversy. David also has broad experience providing domestic and international tax structuring advice in acquisition transactions. David has worked closely with corporate buyers and sellers on various tax aspects of transactions, including U.S. and foreign tax structuring, obtaining IRS private letter rulings, tax attribute planning, and post-transaction integration. David received his BA in Accounting from The Catholic University of America; his JD from Villanova University School of Law; and his LLM, Taxation from Villanova University School of Law.
Mark Young is a Managing Director with Alvarez & Marsal Taxand, LLC in Houston. He specializes in income tax matters and his primary areas of concentration include federal tax planning, compliance, and financial reporting. Mr. Young has advised multinational companies on income tax matters including tax planning, complex business transactions, compliance and financial reporting matters. In addition to considerable experience in ASC 740 (formerly SFAS 109), he has experience in assisting companies with tax department performance improvement and operations. He has served clients in a variety of industries, including energy, private equity, manufacturing, banking, and insurance. Prior to joining A&M, Mr. Young was with PricewaterhouseCoopers' Industry Service Group and federal tax practice in Houston. Previously, he worked in both Ernst & Young’s Dallas office and the firm’s National Tax Department in Washington, D.C. Mr. Young earned his bachelor’s degree in business, with a concentration in finance, from Washington University in St. Louis. He also earned a law degree from the University of Texas School of Law. Mr. Young is a member of the State Bar of Texas and is a licensed Certified Public Accountant (CPA) in the state of Texas.
Thomas H. Young is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Chicago office. Tom has a broad range of experience in the taxation of complex transactions, with a concentration on mergers, acquisitions, dispositions and reorganizations, as well as general international tax planning for U.S. and foreign public companies and closely held businesses. Tom’s mergers and acquisitions experience has encompassed private equity sponsors and public and closely held strategic buyers in domestic and cross-border transactions involving domestic and foreign corporations, subchapter S corporations, partnerships and limited liability companies. In addition, he has advised U.S. and non-U.S. public companies, closely held businesses and foreign investment funds on a broad range of general international tax planning matters. Tom has presented at a number of international tax seminars. He received his J.D., cum laude, from the University of Michigan Law School in 2002, and his A.B., cum laude, with highest departmental honors, from Kenyon College in 1999. Tom is admitted to practice in Illinois. Tom graduated from the University of Michigan Law School, J.D., cum laude, and from Kenyon College, A.B., cum laude.
Janette Zive is a partner with the International Tax Services team at PricewaterhouseCoopers LLP Canada in Toronto. Janette has been consulting on U.S. corporate tax for multinational companies since 1996. She has advised numerous multinational companies, including those providing financial services, on a variety of US domestic and international tax matters, including: US withholding, information reporting and income tax treaty matters (such as passive foreign investment company and FATCA - related matters); cross-border and domestic acquisitions; financial transactions, divestures and reorganizations of entities (including investment funds); financing, factoring, and licensing transactions; repatriation planning; and fund structuring. Janette has co-authored numerous articles that have appeared in a variety of US and Canadian publications including the Journal of International Taxation, The Tax Advisor, CCH International Tax Newsletter, Federated Press’ International Tax Planning Journal, the Derivatives Financial Products Report, the International Fiscal Association and Canadian Tax Foundation reports, as well as PwC’s Investment Management Seminar and Banking Review publications. She has also been a speaker at a variety of tax seminars including the PwC Investment Management Tax Seminar, the U.S. tax developments and cross-border financing seminar for the Tax Executive Institute (TEI) and various tax courses organized by Federated Press, the Part-Time Tax LL.M Program offered by Osgoode Hall Law School and the seminar on cross-border stock option plans offered by The Employee Ownership & Incentives Association. Janette obtained her LL.B from Osgoode Hall Law School in 1993 and her LL.M in United States Taxation from New York University School of Law in 1995. She was called to the Ontario Bar in 1996 and the New York State Bar in 1998.
Joanna Zong is a tax senior manager in KPMG’s New York Financial Services, Federal Tax Practice. She has more than 8 years of experience serving multinational public and private banking corporations. Joanna has extensive experience in preparation and review of interim and year-end income tax provision for large multi-national domestic and foreign financial institution clients. Joanna is in charge of tax compliance projects for large domestic and international financial institution clients, including both tax preparation and review of client prepared consolidated tax returns. Joanna conducts research and draft technical memoranda related to international, federal and multi-state income tax issues. Joanna is often involved in tax audits and responding to inquiries and notices from the IRS and other tax authorities. Joanna consults with her clients on technical, legislative and tax planning matters. Joanna earned her Bachelors of Arts in English from Nanjing University, China; her Master of Business Administration from College of Saint Rose; her Master of Professional Accountancy in Taxation from Indiana University and is a Certified Public Accountant in New York.
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