SUMMARY:

• Built tax function and tax department from the ground up at two publicly traded $350 million a year hi - tech software developers.
• Reduced potential future effective tax rates by 11% through internal revenue code interpretations, including, but not limited to implemented changes in the international tax structure of the organization.
• Created international legal/tax structure limiting foreign tax exposure and facilitating US cash repatriation of earnings.
• Reorganized worldwide subsidiaries for multinational organization to create manufacturing as well as transfer pricing efficiency.
• Experience in over 165 plus countries worldwide, particularly Europe and the Confidential Rim.
• Involved in over 20 mergers and acquisitions in a due diligence capacity, ranging in size from $10 to $350 million.

PROFESSIONAL EXPERIENCE:

Confidential, El Granada, CA

Managing Director

Responsibilities:

• providers for hi-speed banking and vaulting transactions.
• Functions include IP protection, intercompany agreements for transfer pricing and financial statement and tax return preparation.
• Establishing all banking, insurance and payroll relationships.

Confidential, Santa Clara, California

Senior Tax Director

Responsibilities:

• Responsible for all tax functionality on a worldwide basis.
• Responsible for all transfer pricing policies and procedures from both a tax planning and operational basis.
• Structured transfer pricing agreements and ERP systems for the facilitation of inter-company transactions of three new subsidiaries for the purpose of cash repatriation.
• Defended more than $9.2 million in R & D deductions currently under audit by the Inland Revenue department in Singapore.
• Saved the organization more than $400,000 in professional fees by elimination of unnecessary services and additional internal preparation.
• Responsible for various special projects including the implementation of tax provision software and business continuity planning.
• Responsible for the preparation and accuracy of tax provision under Confidential 740.
• Prepared stock based calculations pursuant to Confidential .

Confidential, West Boylston, Massachusetts

Managing Director

Responsibilities:

• Prepared FAS 109, FIN 18, FAS 5, FIN141R and FIN 48 calculation for both domestic and international subsidiaries of several multinational corporations.
• Conducted transfer pricing studies for multinational corporations, including updating existing agreements, drafting agreements for inter-company transactions, setting the transfer price based upon variety of factors including modeling of transfer pricing methodologies.
• Reviewed intercompany transactions to determine accuracy for transfer pricing purposes.
• Performed earnings and profits study for multinational corporations for the purpose of declaring a dividend and determining tax-free repatriation of cash through the return of capital.
• Performed study to determine initial FIN 48 liability for 165 international subsidiaries of a multi-billion dollar multinational corporation, based upon results, updated all international transfer pricing agreements to reflect changes made.
• Instrumental in the preparation or review of forms 5471, 5472, 8865, and 1118, including Section 956 analysis.
• Responsible for compliance returns for federal, state and international purposes for a variety of clients.

Confidential, Acton, Massachusetts

Director of Taxation

Responsibilities:

• Responsible for overhaul of legal and tax structure to facilitate the repatriation of cash from international subsidiaries.
• Reviewed FAS 109 FAS 5 FAS 123R and FIN 48 calculations for year end provision and FIN 18 calculations for includable corporation’s calculation for interim reporting periods.
• Prepared transfer pricing agreements, updated all transfer pricing studies including analysis of existing agreements to determine correct percentage and methodology.
• Prepared foreign tax credit (Form 1118) including calculation pursuant to Section 956.
• Responsible for the sale and movement of Intellectual Property to a BVI and subsequent tax free royalty accumulation for both cash repatriation and tax planning for future acquisitions.
• Incorporated subsidiaries in the Philippines ( Confidential ), Ireland and China for the purpose of reducing worldwide effective tax rate through tax holidays, low tax rates and manufacturing efficiencies.
• Reviewed and approved a tax department budget of $2 million, including all tax returns, budgets and tax account adjustments.

Confidential, Framingham, Massachusetts

Tax Director

Responsibilities:

• Responsible for all domestic and international tax policies and procedures, including all worldwide tax planning.
• Prepared all QST/PST/and GST documentation for three Canadian subsidiaries.
• Responsible for tax provision, including all FAS 109, FAS 5 and FIN 18 adjustments as they relate to the organization worldwide.
• Set transfer price between parent and subsidiaries and drafted all intercompany transfer pricing agreements.
• Responsible for due diligence related to six mergers and acquisitions ranging in size from $10 to $300 million.
• Supervised and evaluated performance of three staff professionals.
• Responsible for the recovery of more than $5 million through effective tax planning.
• Responsible for Global Business Expansion and Intangible Property Structuring Strategy Project. The object of the project is to ensure the corporation has the proper legal structure to facilitate mergers and acquisitions, as well as migrate intellectual property ownership to tax friendly jurisdictions to achieve the lowest effective tax rate possible. After implementation, ensure procedures are in place to maintain and monitor tax rate for fluctuations

Confidential, Honolulu, Hawaii

Senior Tax Manager

Responsibilities:

• Dealt with a variety of international tax issues for both incoming and outgoing corporate entities.

Confidential, Los Angeles, California

Tax Manager

Responsibilities:

• Involved with the preparation and subsequent review of consolidated corporate returns.

Confidential, Hartford, Connecticut

Tax Senior

Responsibilities:

• Prepared individual, corporate exempt-organization and various other compliance returns.
• Involved with various state issues.