Eric Sapir Email & Phone Number

London, Gb

London, Gb

• Assist multinational corporations throughout the bankruptcy life cycle by performing pre-petition tax analysis, developing a bankruptcy tax workplan, performing Section 382 analysis, cancellation of indebtedness income computations, attribute preservation planning and post-emergence reorganization planning and tax support• Determine ownership changes pursuant to Internal Revenue Code Section 382, calculate the annual Section 382 limitation and any increases to such limitation pursuant to Notice 2003-65• Craft complex tax technical memorandums providing both domestic and foreign transaction-related structuring advice to Fortune 500 companies and private equity firms. Transactions include tax-free reorganizations, taxable acquisitions, dispositions, liquidations, and spin-offs• Perform tax due diligence in connection with strategic and investment acquisitions of C-corporations, S-corporations, limited liability companies, and partnerships, and write reports summarizing material federal income tax exposures. Information reviewed includes financial statements, tax returns, FAS 109 provision workpapers, FIN 48 reserve schedules, private letter rulings, tax opinions, internal memorandums, revenue agent reports, debt agreements, acquisition documents and other legal documents• Conduct analyses of both stock basis and earnings and profits in order to determine the most tax efficient acquisition and funding structure

Worldwide, Oo

• Specialize in Tax Controversy Services for corporate, partnership, and individual clients• Represent clients before the Internal Revenue Service and advise clients on their examination strategy• Prepare adjustment protests, penalty abatement letters, and correspondence document submissions to the IRS• Correspond with IRS Examination and Appeals departments to ensure timely conclusion of outstanding tax matters • Research and prepare memorandum on numerous areas of tax law, including: transfer pricing, depreciation, deductibility of expenses, penalty abatement and the interaction between customs law and taxation• Advise clients on restricted transactions and tax shelter regulations to ensure compliance with IRS guidelines

Washington, District Of Columbia, Us

• Conducted examinations and audits of individual taxpayers, corporations and partnerships• Analyzed taxpayer records and filings, while informing taxpayers of tax law rules and regulations• Gathered facts and applied tax law to determine taxpayer deficiencies or refunds• Audited and reviewed forms 1040, 1041, 1120, 1120-S, 1065 and Schedule K-1• Extensively trained in tax law, revenue rulings, revenue procedures and tax court decisions

J.D., Law

Bachelor Of Science (B.S.), With Honors