Brian Gryder, Jd Cpa Email & Phone Number

California, United States

San Jose, Ca, Us

On Disability leave until estimated return on Mar-2025Implement tax-saving strategies through effective collaboration, leadership, and supervision, achieving significant financial results for businesses, individuals, and trusts.• Lead restructuring of 29 business entities post-Tax Cuts and Jobs Act (TCJA), saving $3M and minimizing Global Intangible Low-Taxed Income (GILTI) through team-based modeling and careful IRS guidance monitoring.• Collaborate across departments to save $30M tax, developed a tax-free Controlled Foreign Corporation (CFC) sales strategy using IRC §1248 and §245A.• Supervise employee expatriate tax adjustments, working closely with HR teams to optimize pay adjustments.• Manage the filing of final Internal Revenue Service (IRS) Form 3520 for Intentionally Defective Grantor Trust (IDGT) while overseeing a multi-year exit strategy.• Lead multi-year planning to minimize U.S. assets for expatriated visa holders and their resident spouses.Transition Toll Tax (IRC §965):• Collaborate with stakeholder advisors to save $1.9M by rebuilding 20 years of Earnings and Profits (E&P), identifying inheritance and buyout adjustments.• Spearhead efforts to reduce foreign E&P by $750k through team-based analysis of bad debts.Transfer Pricing:• Manage transfer pricing adjustments to minimize GILTI inclusions.• Lead functional analysis for a Research & Development (R&D) cost-plus strategy.Penalty Reduction:• Partner with legal teams to prepare IRS Form 14457 to reduce Foreign Bank Account Report (FBAR) penalties from $1.2M to $50k.• Manage abatement of penalties on late-filed international forms.

• Earned over 250 hours of CPE credit to reinstate Active CPA license • Implemented budgeting for nonprofit • Managed estate of intestate uncle

Newark, Ca, Us

Managed foreign aspects of accounting for income tax under ASC-740, return compliance, and reorganizations. Prepared transfer pricing documentation under sec 482. Wrote or reviewed transfer pricing studies. Mentored staff.• Minimized risk of critical errors and omissions in income tax provision and tax returns by analysis, tax research, and writing supporting documentation. • Saved 200 hours by directing and preparing Forms 5471, earning recognition by owners.• Directed strategic roadmap for a revamp of worldwide TP studies by engaging advisors and developing "best practices" documentation.• Implemented tax-planning strategies for 3 corporate restructurings and a division sale. Includes preparing 50 new TP studies; documenting support for "Buy ins"; and pushdown of historical tax attributes. • Earned each quarter's maximum bonus.• Acclaimed by CFO as department’s “insurance policy” under Sarbanes-Oxley (SOX).

Westminster, Co, Us

Managed mergers and acquisitions (M&A) due diligence, worldwide tax provision and tax return workpapers, transfer price adjustments, Subpart F inclusions and exceptions, Foreign Tax Credit (FTC), and SOX 404 controls. Reviewed transfer pricing documentation, and expatriate tax issues. • Saved 240 hours by improving the provision analysis.• Reduced chance of errors and omissions on both provision and return by developing a tax accounting checklist to manage integration process for 18 acquisitions and an off-shored Intellectual Property (IP) structure.• Mitigated regulatory risks by leveraging TP software to validate historical studies for IRS audit defense support, successfully earning recognition by financial auditors.• Saved 200 hours in Form 5471 compliance by developing automated analysis work papers that linked into tax software. • Recognized by CFO as Employee of Quarter.

Graduate Certificate, Business/Corporate Communications

Juris Doctor, Business Law

Bachelor Of Science, Cum Laude, Accounting