Tax, Business and Estate Planning Attorney

Tax, Business and Estate Planning Attorney

Federal and International Tax Research and Planning AttorneyDeveloped tax saving strategies, and monitored and reported new tax legislation for the J.C. Penney group of companies. Reviewed newly implemented tax strategies for accuracy and advised the Tax Director on tax implications and financially beneficial alternatives for growth and cost saving initiatives. Advised on transfer pricing policies for intercompany transactions and reporting requirements for domestic and foreign mergers, acquisitions and reorganizations. Supported capital investment committee by advising on cost recovery issues for new asset acquisitions. Successfully negotiated the reduction of proposed tax adjustments from approximately $20 million down to approximately $1 million with a foreign tax authority. Developed a transfer pricing policy with foreign subsidiaries allowing deferral of tax on earnings resulting in an increase in available cash for day-to-day operations.

Advised clients on outbound and inbound tax planning including restructuring, transfer pricing, intellectual property migration and compliance projects. Appointed to BDO’s International Center of Excellence (“ICE”) specialty practice responsible for advising BDO offices throughout the world on domestic and foreign tax strategies. Managed compliance and tax provision projects for both U.S. and international clients. Advised multinational retailer on transferring trademarks, tradenames and goodwill to foreign holding company resulting in a lower worldwide effective tax rate and additional cash for operations. Analyzed transaction costs of steel fabrication client’s acquisition of competitor and developed support for deducting approximately $12 million of costs associated with the acquisition instead of capitalizing these costs. Advised software development client on structuring European operations to include a low tax intellectual property holding company and financing company resulting in a lower worldwide effective tax rate and additional cash for operations.

Assisted and managed international tax engagements involving strategic planning for large corporate clients including domestic and cross-border restructuring, development of financing strategies, minimization of effective tax rates, utilization of foreign tax credits and migration of intangibles.

Assisted in various federal, international and state tax matters involving large corporations and partnerships. Represented clients in consulting, compliance and IRS audit engagements.