Provide global tax advice for business segments providing a diverse mix of retail and commercial appliances. Participate, coordinate and manage extensive tax projects involving operations globally. Responsibilities include leading major restructurings/projects, mergers, acquisitions, divestitures and financings. Interact with and manage outside advisors (CPAs, attorneys, valuation experts, etc.) on achieving project objectives and meeting management, business and investor expectations. Work with Treasury, Accounting, Legal and other corporate functions in successfully implementing pre- and post- closing transactions. Participate extensively in quarterly and annual review of tax accounting processes including FAS109, FIN48, APB23 and ETR calculation and forecasting. Manage tax planning team of ~5 direct reports and ~30 indirect reports.

Representative projects include:

 Led implementation of new global holding company structure providing for future tax-free repatriation to U.S. in excess of $4B and optimization of foreign tax credits in excess of $300M
 Led global structuring for potential $2B joint-venture with material operations in Brazil, China, Italy, U.S. and China
 Developed preliminary analysis of Swiss principal structure for a material business segment
 Participated extensively in $150M sale of Chinese subsidiary to strategic buyer
 Participated extensively in preservation and/or utilization of deferred tax assets globally

Provided global tax advice for business segments providing a diverse mix of products and services in the oil and gas industry. Participated, coordinated and managed extensive tax projects involving operations globally. Responsibilities included leading major restructurings/projects, mergers, acquisitions, divestitures and internal financings. Interacted with and managed outside advisors (CPAs, attorneys, valuation experts, etc.) on achieving project objectives and meeting management, business and investor expectations. Worked with Treasury, Accounting, Legal and other corporate functions in successfully implementing pre- and post-closing transactions involving intercompany accounts, cash extraction, tax groupings, accounting recording and reporting and other integration/divestiture related activities. Participated in quarterly and annual review of tax accounting processes including FAS109, FIN48, APB23 and ETR calculation and forecasting. Manage tax planning team of ~12 direct reports.

Representative projects included:

 Participated extensively in removing material weakness for income taxes including reconciliation of tax accounts, uncertain tax positions and development/improvement of internal processes/controls
 Led implementation of new internal financing structure for global operations involving in excess of $10 billion in leverage
 Led development and implementation of change in corporate domicile from Switzerland to Ireland

Provided tax advice for business segments providing security, fire, safety, flow control and electrical/metal products and services to retail, commercial and industrial customers. Participated, coordinated and managed extensive tax projects involving operations in the North America, South America, Europe and Asia Pacific regions. Responsibilities included analysis, planning, drafting and negotiation for mergers and acquisitions, joint ventures, divestitures, corporate restructurings, financings, transfer pricing, and related controversies. Interacted with and managed outside advisors (CPAs, attorneys, valuation experts, etc.) on achieving project objectives and meeting management, business and investor expectations. Worked with Treasury, Accounting, Legal and other Corporate functions in successfully implementing pre- and post-closing transactions involving intercompany accounts, cash extraction, tax groupings and other integration/divestiture related activities.

Representative projects included:

 Advised on numerous planning projects desired to achieve business, tax, treasury and other corporate objectives including the:
o separation of the company into 3 stand-alone, publicly-traded companies through a spin- off;
o opportunity to divest an existing business line through either a spin-off or sale
 Advised and managed structuring, due diligence, drafting and negotiation for the tax
consequences of over 70 acquisitions and divestitures

Responsibilities included analysis, planning, drafting and negotiation for mergers and acquisitions, joint ventures, divestitures, financings, corporate restructurings, financial products, private equity and hedge funds and related controversies.

During this time, I also worked for Troutman Sanders LLP and Chamberlain Hrdlicka. Details available upon request.