James Diller Email & Phone Number

Provide tax consulting and controversy management to firm's clients on their more complex technical issues.

During my GM career, I held various leadership positions responsible for compliance oversight, tax planning, and controversy management. The first half of my career mostly involved US Federal and S&L taxation, whereas, the last 12 years was focused on US and non-US international tax issues. Among my areas of expertise were: Managed GM's of global transfer pricing: developed and executed global transfer pricing strategies, including drafting agreements and policies; executed processes for the timely review of tested party results and for Fin 48 analyses; actively managed the preparation of global economic studies to document/ defend results; managed transfer pricing controversies in over 20 countries (including emerging markets); and obtained CA relief, APAs, and rulings numerous jurisdictions.Cross-border mergers/acquisitions/dispositions: due diligence reviews (tax); participated in negotiations; developed optimal tax structures and funding; strategies to maintain or obtain post-transaction tax attributes and/or obtain; and successfully defended transactions in multi-jurisdictional audits. Legal entity and business (trade-flow) structuring and restructuring including: tax-efficient ownership/holding company structures; revised supply chain structures; and trading companies.Joint ventures/ cost-sharing agreements/ partnerships and cooperative agreements.Indirect tax (e.g., VAT, customs) in numerous jurisdictions.Licensing/ transfer of technology and other intangibles.R&E credits and allocation of R&E expenses.Developed and executed a wide variety of complex corporate and partnership tax initiatives.Managed numerous tax audits and administrative appeals involving US federal tax and State & Local tax issues.Recruited and developed professionals for all areas of taxation.

Llm, Taxation

Jd, Law

Activities and Societies: Law Review- Research Editor Willis Society (top 10%)