Tax professional with significant multinational public corporation, Big Four accounting firm, and law firm experience. Research and planning, tax accounting, FAS 109, FIN 48, Sarbanes-Oxley (SOX), tax audits and appeals, international operations, securities filings. Attorney, LL.M in Tax, and CPA.
Tax professional with experience as Chief Tax Officer of a global public corporation, Tax Partner at a Big 4 CPA firm, and Tax Partner at a law firm. Experienced in tax accounting and reporting, including FIN 48 and FAS 109, cross border transactions and tax treaties, tax returns, tax audits and controversies, research and planning, SOX and SEC compliance, and leading a tax department.
Global, Public, Multi-Billion Dollar Insurance Company
Vice President – Taxes 2006 - Present
Chief tax officer responsible for all federal, foreign and state taxes, FAS 109 tax accounting, tax planning and research, M&A, SOX compliance, tax audits/controversies, tax returns, and SEC/NAIC tax reporting.
• Manage and improve the tax accounting and reporting function, including ASC 740 compliance, FIN 48 disclosure, FAS 109 tax accounting issues, and quarterly tax provisions.
• Develop and manage cross border transfer pricing and operating guidelines for services between international locations including the U.S., U.K., Bermuda, Canada, Ireland, and Singapore.
• Plan global corporate restructurings to save 50M of withholding taxes on fixed income payments.
• Maximize utilization of foreign tax credits and monetize 20M of foreign tax credit carryovers.
• Consolidate the tax results of U.S. and foreign corporations, branches, and subsidiaries.
• Structure financings and global investments to minimize income and withholding taxes.
• Responsible for all tax audits, achieving a 70M reduction of tax expense by characterizing a branch disposition as an assumption reinsurance transaction and negotiating with IRS Appeals.
• Plan the restructuring of an acquired company to minimize post-acquisition state taxes.
• Manage SOX and internal audit compliance/audits and SEC/NAIC tax reporting and footnotes.
• Analyze proposed legislative and regulatory developments and develop strategies to maintain or lower the effective tax rate in anticipation of changes.
• Minimize cascading excise tax liability and negotiate an audit settlement with the IRS.
• Reduce costs through effective management of tax department resources.
Big 4 CPA Firm Serving Clients in Manufacturing, Technology, Finance, and Other Industries
Tax Partner 2001 - 2006
Tax partner advising multinational clients on tax and tax accounting consequences of global transactions.
• Structured business expansions to Europe and Asia, including creation of holding companies and finance subsidiaries in treaty jurisdictions to minimize income and withholding taxes.
• Restructured supply chains to minimize taxation through contract manufacturing arrangements, transfer pricing, and the use of hybrid entities.
• Structured global acquisitions and financings to minimize worldwide taxes, maximize use of losses and foreign tax credits, and minimize Subpart F income.
• Managed compliance with regulatory requirements and new developments, including Sarbanes-Oxley, SEC tax reporting, and communications with senior management.
• Analyzed the tax accounting and reporting implications of proposed transactions.
Global, Public, Multi-Billion Dollar Manufacturer
Senior Vice President – Taxes 1993 - 2001
Chief tax officer responsible for all federal, foreign and state taxes, FAS 109 tax accounting, tax controversy issues, tax returns, and SEC tax reporting. Planned, implemented, and communicated creative strategies and transactions designed to minimize current tax payments and maximize earnings
per share. Reported directly to the Chairman and communicated regularly with senior management.
• Planned and implemented the tax-free spinoff of a multi-billion dollar public company and obtained a favorable IRS ruling after modifying the pre-spinoff consolidated structure.
• Achieved a 50M tax refund under special loss carryback rules by developing a multi-year plan
to manage the timing of key items of income and expense.
• Structured domestic and international acquisitions, dispositions, joint ventures, and financings, including negotiation of complex tax indemnification and tax sharing agreements.
• Worked closely with treasury and corporate development to structure financings and investments.
• Managed SEC tax reporting and preparation of tax footnotes to financial statements.
• Successfully negotiated sensitive tax audit issues and worked closely with outside counsel to manage the litigation of a 400M Tax Court case.
• Structured acquisitions to avoid the loss limitation rules of Section 382 and to maximize the advantages of Section 338 elections to step up the tax basis of acquired companies.
Law Firm Serving Clients in Financial Services, Real Estate, Manufacturing, and Other Industries
Tax Associate/Tax Partner 1982 - 1993
Tax attorney advising multinational clients regarding the federal, state, and foreign tax aspects of structuring mergers and acquisitions, debt financings, tax-favored investments, inbound and outbound global investments, and compensation issues.
PROFESSIONAL LICENSES AND BAR ADMISSIONS
Accounting: CPA, New York
Law: New York State Bar; U.S. Tax Court; U.S. District Court
School of Law, Degrees: J.D. and LL.M in Taxation
Degree: B.B.A, Summa Cum Laude
Major: Public Accounting