♦ Develop and execute tax plans for operations in North America, Asia, and Europe to ensure the worldwide group is operating on a tax- and cost-efficient basis. ♦ Monitor, research, and model the impact of U.S. and foreign tax law changes.♦ Review and defend the company’s global tax positions on audit, including the defense of transfer pricing matters. ♦ Monitor and interpret tax treaties to ensure the organization’s cash is deployed efficiently while recommending structural changes where required. ♦ Liaison with the control team to ensure all transactions and positions are compliant with ASC 740.

Master of Taxation program

Provided corporate tax services to US-based clients through TaxForce, including tax controversy, entity rationalization, ASC 740 compliance, transfer pricing, and global tax compliance reviews. Identified tax savings opportunities and process improvements to mitigate tax liabilities and enhance controls. Provided interim director services to bridge gaps in the clients' tax function. Clients included Weatherford International plc, Micro Focus International plc, and Knowles Corporation.

♦ Accountable for the worldwide tax function. Recruited and trained staff, outsourced routine tasks, retained value-added work, and established goals for the team. ♦ Responsible for the ASC global tax provision; assessed uncertain tax positions, analyzed the effective tax rate, drafted financial disclosures, and managed the financial audit. ♦ Generated transfer pricing studies and documentation for intercompany transactions, including tangible asset transfers and leases, use of intangibles, and product and service sales. ♦ Collaborated with executive management and the board on business development. ♦ Coordinated the defense of tax audits and worked with tax authorities around the world. ♦ Generated perpetual tax savings by implementing a holding company structure with cash pooling, successfully closing audits, implementing an IC-DISC, and structuring the shutdown of foreign operations tax efficiently. ♦ Reviewed domestic and foreign tax compliance calculations, forms and disclosures. ♦ Analyzed tax legislation, summarized impacts, and recommended strategic actions.♦ Implemented repatriation strategies to access offshore cash tax efficiently. ♦ Advised on mobilization and expatriate tax issues.♦ Managed property tax and indirect taxes, including VAT and GST. ♦ Trained associates on FBAR and FATCA compliance.♦ Identified and secured state and local grants as well as credits for job creation.♦ Drafted and reviewed tax language for acquisition agreements and customer contracts. ♦ Automated the sales & use tax process, reducing G&A costs and average DSO on customer receivables.

* Directors report to managers in ConocoPhillips hierarchy.♦ Provided advice on cross-border and host country tax issues.♦ Reviewed and modeled foreign source income, foreign tax credit utilization, as well as dual consolidated loss, OFL and ODL positions. ♦ Directed and reviewed ASC 740 compliance and monitored SoX 404 controls. ♦ Advised management of expected implications for new tax legislation.♦ Reviewed compliance, including Forms 1042, 1118, 5471, 5713, 8832, 8858, 8865, and 1120-F.♦ Secured tax benefits through Sec. 165(g) worthless stock planning.♦ Maximized Sec. 863(b) profits on cross-border sales, generating significant annual tax benefits.♦ Advised on tax treaty, permanent establishment, and withholding tax issues.♦ Developed and advised on plans to lower the effective tax rate and mitigate cash taxes.♦ Assisted with managing examinations and developing responses for tax audits. ♦ Implemented plans to spin-off the refining operations; performed a detailed review of the tax sharing agreement, calculated taxes for the carve-out financials, and worked to ensure no material tax was incurred. ♦ Responsible for 19 directors and staff.

♦ Tax officer accountable for the global tax function and management of advisory firms.♦ Rebuilt the tax function, designed processes for efficient compliance while mitigating tax risks.♦ Partnered with operational leaders on business development opportunities.♦ Worked with executive leaders to establish a Swiss Principal structure.♦ Responsible for all of the global ASC 740 tax provision processes and the financial audit of taxes.♦ Designed and implemented processes for claiming Sec. 199 manufacturing benefits.♦ Established a financial shared service center in Poland.♦ Advised management on pending tax legislation, the impacts, and recommended actions.♦ Developed procedures and controls for SOX compliance.♦ Advised HR on the tax implications of employee benefits, including stock compensation plans.♦ Filed and managed competent authority (i.e., MAP) claims.♦ Reviewed domestic tax filings and income tax filings for subsidiaries located in Europe, Asia, Australia, and Latin America.♦ Responsible for the company's transfer pricing policy, training, and compliance, including pricing for products, services, asset sales and leases, loans, and cross-border use of intangibles.♦ Provided advice and recommendations on tax treaty and permanent establishment issues.♦ Managed a team of 8 professionals, including members co-sourced from KPMG.

Due to the impending sale of Perot Systems, I transitioned to Deloitte's Dallas office on an interim basis while considering other positions in industry. ♦ Assisted partners with the development of tax accounting systems, procedures, and controls. ♦ Reviewed international structuring, transfer pricing, and repatriation strategies. ♦ Responsible for identification of the clients’ needs and implementation of solutions. ♦ Generated proposals and scheduled complex cross-border projects.

♦ Advanced through a series of promotions to the head-of-tax role managing 20 professionals. ♦ Directed IRS large case and foreign tax audits, all tax compliance and the financial reporting of income taxes under FAS 109 / ASC 740. ♦ Rationalized legal entity structures for tax, FX and G&A savings. ♦ Prepared SEC disclosures regarding taxes and directed the financial audit of the tax provision. ♦ Drafted tax sections for acquisition, customer, vendor and intercompany contracts.♦ Interfaced with executive management and the board of directors on tax matters. ♦ Managed relationships with external advisory firms to ensure maximum value was derived. ♦ Expanded operations into Software Technology Parks and Special Economic Zones in India and the Philippines.♦ Designed and implemented cash repatriation plans under Sec. 965 to fund US acquisitions. ♦ Performed due diligence and structured purchase agreements for domestic and foreign acquisitions.

♦ Provided hands-on direction for international tax matters including US taxation of foreign operations, transfer pricing and ASC 740. ♦ Supported foreign tax audits. ♦ Advised Corporate Legal on VAT, withholding, permanent establishment, and tax indemnity issues on acquisition agreements and customer contracts. ♦ Reviewed or prepared the international compliance for the federal returns, including Subpart F, foreign source income, and foreign tax credit calculations, prepared IRS disclosures and elections. ♦ Worked with Legal, Operations, and Sr. Management to design and execute tax planning strategies.

♦ Established the company's international tax compliance and transfer pricing functions. ♦ Created all processes, procedures and controls for ASC 740 reporting on the international operations. ♦ Recruited and trained direct reports and administered departmental budgets. ♦ Structured customer contracts to minimize local taxes.♦ Led project to minimize Subpart F dividends, materially reducing the company’s annual tax burden.♦ Established transfer pricing policies and created the initial Sec. 6662(e) documentation.♦ Prepared or reviewed Forms 1118, 1120-F, 5471, 8858 and 8865.♦ Advised on the application of tax treaties and withholding rates.♦ Drafted responses for IRS and foreign tax examinations. ♦ Performed cross-border tax planning for new sites.

♦ Reviewed and approved non-US tax filings and tax audits, developed responses for IRS requests, interfaced with M&A on business development. ♦ Monitored transfer pricing targets. ♦ Managed international portions of the US consolidated return as well as the foreign sales corporation (“FSC”). ♦ Reviewed worldwide current and deferred tax provisions. ♦ Forecasted TI’s total taxes and prepared the five year tax plan. ♦ Reviewed and updated all tax audit reserves. Continuously analyzed effective tax rate concerns.♦ Reviewed or prepared Subpart F, Sec. 956, E&P, foreign source income, foreign tax credit, and inside as well as outside basis calculations.

Prepared IRS Forms 1040, 1065, 1118, and 1120. Researched corporate, individual and employment tax issues.