Policy work focused on the OECD’s Two-Pillar Solution, with a focus on Pillar Two implementation.Maintain ownership of transfer pricing for global cost allocations and M&A activity. Oversee policy for transfer pricing topics.

Deal with all aspects of developing, executing, and maintaining Amazon's inter-company transfer pricing policies. Projects include IP planning, EU State Aid analysis, APAs, and 2017 TCJA (US tax reform). Day to day experience includes FIN48 analyses, review of tax provision, assistance with preparation of statutory financials and foreign tax reporting, drafting inter-company agreements, collecting and gathering data and information, analyzing and setting pricing consistent with the arm's-length principal, preparing transfer pricing document reports, assisting with audits, analyzing business and planning strategies, M&A integration, and managing and working with outside advisors.

Legal entity forecast and modeling lead for business restructuring which resulted in significant benefits for the company and reduction of potential BEPS exposure. Manage planning initiatives with tax provision, corporate income tax, indirect tax, and non-tax (business, customs, IT, legal, etc.) implications. Deal with all aspects of developing, executing, and maintaining Amazon’s intercompany transfer pricing for Europe. Evaluation and implementation of certain TP internal controls resulting in a more defensible internal/external audit platform for TP in the organization.

Drafted global transfer pricing documentation in accordance with U.S. I.R.C. Section 482 and the OECD Transfer Pricing Guidelines. Helped implement inter-company transfer pricing policies and international tax restructurings. Prepared inter-company services studies for global cost allocations. Created transfer pricing adjustment models for multiple entities that perform various inter-company services, including R&D, manufacturing, and G&A. Performed analysis and modeling for IP buy-in and platform contribution transactions. Assisted with defense of IRS audits and NOPAs related to the migration of IP as well as inter-company services.

Managed complex global cost allocation for the Company, including interview of senior leadership and detailed evaluation under Treas. Reg. Section 1.482-9 and the OECD Transfer Pricing Guidelines. Analyzed complex IP planning, Subpart F, withholding, and permanent establishment issues. Prepared annual reports for Advance Pricing Agreements with IRS and drafted responses to inquiries from IRS and foreign tax authorities.

Advised clients on the tax consequences of business structuring alternatives. Performed business formation and registration. Drafted real estate contracts, development plans, and template living agreements to ensure compliance with state regulations, statutes, and ordinances (e.g., California Residential Care Facilities for the Elderly (RCFEs) regulations).