Primary Industries: Oil & Gas, Petrochemicals, Sovereign Wealth Funds• working with large government-owned multinationals to better understand BEPS compliance obligations and achieve full compliance, specific focuses include:• working to understand and remediate increased permanent establishment risk;• working to understand, remediate and document BEPS Action 4 and U.S. Treas. Reg. Section 1.385 risk with respect to shareholder loans;• working with international tax colleagues to advise clients on the impact of substance with respect to Limitation of Benefits and Principal Purpose Test clauses on continued applicability of Double Tax Treaty benefits;• working with SWFs to understand applicability of BEPS Action 13 requirements given the difficult / uneven applicability to organizations with largely independent groups embedded within their organizations, specific considerations include the consolidation requirements under applicable accounting standards (e.g., IFRS 10);• working with clients to achieve tax efficient structures while better aligning profitability with key value drivers and economic substance to minimize associated BEPS risks, key considerations include direct CIT, WHT, and understanding availability of treaty benefits.

Primary Industries: Oil & Gas, Chemicals, Medical Devices• Served as lead IRS representative on high profile, strategic transfer pricing cases• Interviewed divisional heads of leading multinationals to better understand key value drivers• Coordinated multiple stakeholders to ensure IRS success at all stages of the dispute (risk assessment, issue selection, information gathering, analysis, adjustment, Appeals, litigation)• Worked with senior members of IRS Transfer Pricing Operations to identify emerging issues• Worked with representatives of IBC, APMA, TPP, and Counsel to achieve consensus with respect to a single, best method for working related transfer pricing issues at every point of contact with taxpayers• Served as an expert reference for APMA economists, IBC economists, and International Examiners regarding cost sharing arrangements and other intangible property valuation issues

Primary Industries: Technology, Pharmaceuticals• Fair market valuation and arm's length valuation of intangible property for tax purposes• Implementation of options pricing theory to price risk for transfer pricing purposes• Developing transfer pricing policies designed to help effectuate operations related goals • Identification of potential tax concerns involved in business restructurings• Developing cost sharing arrangements• Assistance with intangible partnership planning and compliance• Assistance in selection, development and implementation of tax efficient structures to better suit company supply chain and operations• Assisting clients in evaluating tax impact of structuring alternatives of potential mergers and acquisitions• Assisting minority shareholders in analysis of intercompany agreements• Multi-country dispute resolution support and assistance with competent authority / mutual agreement process• Project management and administration for large, globally active clients

• Prepared transfer pricing documentation for IRC Section 6662 and OECD purposes• Provided support with regards to preparing Advanced Pricing Agreement applications, negotiations, and compliance• Performed data analysis and prepared documents to assist clients with regards to the competent authority / mutual agreement procedure process to reduce instances of double taxation• Assisted in preparing support for state level, US IRS level, and other tax authority audits of transfer pricing policies• Worked with clients and client attorneys to develop appropriate intercompany licensing and services agreements for transfer pricing purposes• Devised and executed database searches to perform benchmarking analyses for determining appropriate rates of return on cross border intercompany transactions• Assisted in drafting proposals, reports, document requests and other correspondence, as well as preparation of charts, reports and presentations.

• Directed a team of undergraduate research assistants• Used industry reports and current research to determine and prioritize data needs• Assigned projects in data retrieval and cleaning to research assistants and met regularly to assess progress and provide further guidance

• Principles of Microeconomics (Econ 200), Principles of Macroeconomics (Econ 201), Current Economic Issues in the United States (Econ 367)

• With Professors John Gray and Michael Leiblein, Using: MS Excel, MATLAB, Stata, SAS• Used Excel to construct a large longitudinal data set from 16 years of industry reports• Wrote MATLAB code to prepare summary statistics and find outliers with a goal of identifying miskeyed data points and cleaning the data as necessary• Used available research databases to locate and retrieve additional data as needed• Used SAS to construct latent variables such as firm experience, production technology ratings and others by combining current data with data from outside sources• Researched current economic theory to determine optimal estimation strategies and estimated empirical choice models with Stata

• Beginning French Sequence – FR 111, FR 112, FR 113