Senior professional responsible for the global tax function, including tax planning for the foreign and domestic operations, US and host-country tax compliance as well as ASC 740 reporting.

Summarize trends and developments in legislation for management. Regularly interface with business leaders as a key participant in business development. Manage the financial audit of taxes and develop processes to ensure the company is compliant with ASC 740.

Serve as lead negotiator on tax controversies and proactively manage the company’s transfer pricing policies. Manage relationships with external consultants and vendors to ensure maximum value is derived. Collaborate with department heads to develop sustainable improvements for finance.

* Directors report to Managers in ConocoPhillips hierarchy.

A $58 billion independent oil and gas exploration and production company with over four hundred foreign subsidiaries.

Manager, International Tax*
Lead and oversee the international tax directors and staff. Serve as a technical resource for international and host country tax issues. Direct ASC 740 compliance for the US and foreign subsidiaries. Identify, research and implement tax strategies for the repatriation of earnings and the efficient use of foreign tax credits to reduce the company’s effective tax rate. Assess and model the impact of proposed tax legislation and support the company’s business leaders to efficiently deploy new operations and dispose of marginal assets. Establish a clear vision for the team and set expectations to ensure deadlines are met.

• Secured over $100 million of tax benefits through Sec. 165(g) worthless stock planning.

• Supported business unit leaders to maximize Sec. 863(b) profits on cross-border sales from LNG plants and refineries generating over $10 million of tax benefit per year.

• Facilitated the development and implementation of plans for the spin-off of Phillips66 to ensure no material taxes were incurred on the transaction.

• Supported potential litigation with the IRS on deductions for subsidiary tracking stock by providing robust documentation of the business rational and the events driving worthlessness, resulting in the IRS abandoning the issue in Appeals.

A $2+ billion manufacturer of industrial batteries with over eighty subsidiaries in North America, Europe and Asia.

GLOBAL TAX DIRECTOR

Hired to establish a global tax function. Designed processes for the delivery of cost-efficient tax services while mitigating tax risks. Directed planning for foreign and domestic operations and ASC 740 reporting. Regularly interfaced with executive management as a key participant in business development. Managed the financial audit of taxes and developed processes to ensure the company was compliant with SOX. Interpreted and framed legislative changes for management and deployed strategies to enhance earnings per share and cash flows. Engaged business leaders to provide decision support, serving as lead negotiator on tax controversies and proactively managed the company’s transfer pricing. Collaborated with department heads to develop sustainable improvements for finance. Directed a staff of eight, including professionals co-sourced from KPMG.

• Partnered with executive and operational leaders to establish a Swiss Principal Structure generating $6+ million of annual cash and P&L tax savings.

• Designed and implemented processes for claiming Sec. 199 domestic manufacturing benefits, resulting in $2+ million of annual tax savings.

• Along with operational leaders, deployed a shared service center in Poland, producing $1+ million of annual tax savings.

A $3 billion provider of IT and business services with over sixty subsidiaries in Asia, Europe and North America.

CORPORATE (GLOBAL) TAX DIRECTOR (2005-2007)
Advanced through a series of promotions to the senior tax position based on work ethic, technical knowledge and cross-functional partnerships. Directed IRS large case and non-US tax examinations, income tax, VAT and sales tax compliance as well as the financial reporting of income taxes under ASC 740. Prepared financial footnotes regarding taxes and directed the financial audit of the tax provision. Regularly interfaced with executive management and the board of directors on tax issues. Managed relationships with external consultants and vendors to ensure maximum value was derived. Summarized trends and developments in tax legislation for executive management.

• Successfully defended the 1999 through 2005 tax filing positions of the company resulting in the reversal of $48 million of IRS assessments.

• Worked with executive and operational leaders to expand into Software Technology Parks and Special Economic Zones in India and the Philippines, generating over $25 million of tax savings through 2007 with an additional $60 million of savings expected through 2017.

• Designed and implemented cash repatriation plans under Sec. 965 to fund US acquisitions. Repatriated $45 million at a tax cost below 6.0%.

• Performed tax due diligence and structured purchase agreements for the company’s US and non-US acquisitions.

INTERNATIONAL TAX DIRECTOR
Provided hands-on direction for all international tax matters including US and local compliance for the foreign operations. Developed processes to capture ASC 740 information for the foreign subsidiaries. Developed structuring alternatives to reduce US and local income taxes as well as transactional taxes. Recruited, trained and supervised five direct reports based in Plano, London and New Delhi. Advised legal team on terms for customer contracts, including value-added tax implications, income tax withholding issues, expatriate tax and transfer pricing issues. Developed SOX 404 documentation for the international components of the tax provision. Managed communications with US and foreign tax authorities and developed responses for tax audits.

• Engaged in VAT planning resulting in the mitigation of $500 million of tax for customers in Europe.

• Designed and implemented SOX 404 controls for corporate tax.

• Achieved additional P&L and cash-tax savings by continuously managing the company’s transfer pricing.

INTERNATIONAL TAX MANAGER
Tasked with establishing the international tax function, specifically designed the processes for US compliance of international transactions, including compliance with IRC Sec. 482. Performed or reviewed all work for preparation of the Forms 1118, 5471, 8865, 1042 and related disclosures. Managed transfer pricing documentation and related issues. Implemented effective tax rate reduction plans involving non-US subsidiaries. Advised management on expatriate tax issues. Consulted with operational leaders on tax strategies for Europe and Asia. Supervised two staff members and maintained departmental budgets

• Structured customer contract terminations to avoid $3.5 million of local income tax.

• Established the company’s initial transfer pricing policies and created the initial Sec. 6662(e) documentation. As a result, no transfer pricing penalties or tax assessments were issued by the IRS in its review of the 1999-2005 tax years.

• Led project to minimize deemed dividends, reducing the company’s annual tax expense by $1.5 million.

A $12+ billion manufacturer of semiconductors with approximately seventy subsidiaries in Asia, Europe and Latin America under a publicly traded US parent.

International Tax Analyst
Reviewed and approved non-US tax filings and audits, developed responses for IRS audit requests, interfaced with M&A on business development. Monitored 482 pricing targets. Responsible for international portions of the US consolidated return as well as the foreign sales corporation (“FSC”). Reviewed worldwide current and deferred tax provisions. Forecasted TI’s total taxes and prepared the five year tax plan. Reviewed and updated all tax audit reserves. Continuously analyzed ETR concerns.

An 18+ billion provider of oilfield and construction services with over two hundred subsidiaries in Africa, Europe, The Middle East, Latin America and The Pacific Rim, organized under a publicly traded US parent.

Tax Specialist
Performed tax research for mergers, asset sales and UNICAP issues. Prepared 1120’s, 1118's, 5471's and state tax filings for Halliburton's Energy Services Group. Implemented foreign tax credit plans, repatriation plans and foreign NOL utilization. Exposed to Latin American tax regimes.

One of the largest independent producers of oil and natural gas in the United States. A publicly traded partnership formed by T. Boone Pickens.

Sr. Tax Accountant

Prepared Form 1065 for the Master Limited Partnership, the consolidated 1120 for Mesa Petroleum Co. and numerous state tax filings. Researched partnership and S corporation issues. Responsible for all accounting and tax issues for Boone Co. and Pickens Operating Company (S corporations).

Peat Marwick Mitchell & Co., Amarillo, TX
“Big 8” Public Accounting Firm

Sr. Tax Accountant
Performed tax planning and preparation for individual and corporate clients. Also, recruited and trained new hires.