• Identified, researched and implemented tax planning strategies related to tax minimization that resulted in substantial lowering of effective tax rate and return of hundreds of millions of dollars of capital with minimal tax impact and no APB 23 consequences; monitored tax legislation and other tax laws, and advised management of the impact and opportunities.
• Advised management of current and proposed transactions, including acquisitions and divestitures, and implemented transactions including the integration of acquired businesses resulting in hundreds of millions of tax savings.
• Managed U.S. and global compliance and reporting related to foreign operations to ensure all obligations were satisfied accurately and timely. Was responsible for financial accounting and reporting provision related to foreign operations and ensured SOX compliance.
• Managed non-U.S. audits, determined the related tax exposure, and managed the associated risk resulting in minimal tax payments upon audits.
• Managed transfer pricing, including pricing, reporting, and documentation and ensured BEPS compliant before 2017.
• Managed a team of 9 other international tax professionals, and worked closely with other finance, treasury, business, and legal professionals resulting in coordination of company efforts.
• Managed and worked with outside consultants.

Advised on a wide range of Federal tax and United States Virgin Islands tax issues, tax including tax controversy, income, gross receipts and customs for a wide range of clients. Drafted various corporate documents. Structured clients’ transactions to minimize overall tax. Negotiated and responded to audits and assessments resulting in clients paying no or minimal tax.

Principal, Washington National Tax, International Corporate Services
• Advised multinational companies (inbound and outbound) on a wide range of tax matters, including dual consolidated losses, foreign tax credits, cross-border transactions, repatriation strategies, Subpart F issues, and sovereign wealth investments. Reviewed transactions and tax issues for financial accounting purposes, and sought rulings and advice from Internal Revenue Service related to transactions. Presented at international tax conferences and participated in training of other tax professionals.
• Led a team of professionals to develop white papers and presentations to explain to C-suite and tax professionals of multinational companies the implications and planning opportunities related to major 2010 international tax legislation.
• Led a team of tax professionals across different continents related to tax provision review of a Fortune 500 company.
• Reviewed the international tax positions of major transactions of a Fortune 500 KPMG audit client.
• Advised private equity clients with major foreign investors about the U.S. tax implications of investing in the U.S., including withholding obligations, issues related to holding interest in U.S. real property (“FIRPTA”), and tax reporting obligations. Reviewed tax opinion for prospectuses.
• Advised a domestic Fortune 500 company with headquarters abroad about tax-efficient means of establishing subsidiaries abroad or acquiring companies abroad.

• Reviewed regulations, notices, revenue rulings, revenue procedures and other technical advice memoranda on a wide range of international tax issues, including corporate reorganizations and other cross-border transactions.
• Had primary responsibility for assisting the Deputy Associate Chief Counsel International-Technical with the Office’s technical guidance program resulting in hundreds of guidance being issued and providing taxpayers with more certainty.
• Participated in the drafting of guidance under section 965 (the temporary dividends received deduction provision) that resulted in taxpayers being able to repatriate hundreds of billions of dollars of cash at a 5 percent tax rate; reviewed guidance to implement provisions relating to cross-border activities and transactions and allowing taxpayers to do business more easily without paying tax.
• Formulated positions related to tax audits and litigation and reviewed documents related to tax litigation.
• Participated in the drafting of foreign currency branch transactions regulations, mark-to-market trader election regulations, and Subpart F guidance that allowed taxpayers to engage in business in an evolving economy without paying tax.
• Researched, analyzed, advised, and drafted opinions, rulings, regulations, and other written guidance on international tax issues related to corporate mergers and acquisitions, other corporate and partnership transactions, and cross-border financial transactions and products.

• Researched, analyzed, and advised on a wide range of tax issues for planning, controversy, and litigation purposes.
• Prepared various written documents to support litigation positions and drafted legal opinions and memoranda on complex tax issues.
• Areas of focus included tax accounting, exempt organizations, corporate, partnership, and low-income housing tax credits for single and multifamily housing units.
• Analyzed tax and accounting standards proclamations and guidance and drafted technical documents in support of litigation related to multibillion-dollar tax litigation for oil and gas industry clients.
• Saved clients billions of dollars in taxes through structuring of transactions and controversy and litigation settlements.

• Drafted corporate documents and tax opinions and advised clients and collaborated with other parties about low income housing tax credit syndications and partnership tax issues related to single and multifamily housing units resulting in millions of dollars of tax savings for investors.
• Researched, analyzed, and consulted on a wide range of other tax issues and drafted ruling requests to the Internal Revenue Service

• Served as an in-house tax law resource and consultant for RTC field attorneys and senior management in various divisions and offices throughout the RTC.
• Managed outside tax professionals on a wide range of Federal and state tax issues (including property taxes and special assessments).
• Recommended solutions to tax concerns in the purchase and sale of assets, including operating subsidiaries resulting in hundreds of millions in tax savings.
• Negotiated with the U.S. Treasury Department, the Internal Revenue Service, and states regarding Federal and state tax law and policies affecting insolvent savings and loans resulting in billions of dollars in tax savings.
• Through mid-1992, also served as principal legal consultant on pension issues of insolvent savings and loans.
• Interpreted, applied and advised about FIRREA and insolvent savings and loans in receivership and conservatorship.
• Analyzed and negotiated with states on the U.S. constitutional and Federal banking rules related to the ability of state and local governments to tax the property or transactions of insolvent savings and loans under the control of the RTC. Persuaded one state not to pursue a $4 billion tax issue and other state and local governments not to pursue hundreds of millions of dollars.

(On loan from RTC)
• Provided expert advice and assistance related to the development of plans, strategies, policies, and initiatives for overseeing and monitoring the activities of the Resolution Trust Corporation.
• Performed special legal and other analyses and assignments for the Executive Director, including assisting in the preparation of position papers for Congressional hearings, board meetings, and conferences with the Secretary of Treasury, other Oversight Board members, and other senior officials in government.
• Researched, analyzed, coordinated, developed, and negotiated sensitive issues on behalf of the Executive Director related to Federal banking laws and other Federal laws and regulations.