Marcus Shore Email & Phone Number

Charlotte, NC, US

Charlotte, North Carolina, United States

The focus of my position is federal and state tax planning, controversy, and the review of tax legislation.

Charlotte, North Carolina

• Developed and implemented procurement strategy to enable wind and solar projects to qualify for safe harbored renewable energy tax credits.
• Completed review of regulated utility formula ratemaking to identify and remediate normalization violation, avoiding potential loss of accelerated depreciation and ITC.

Charlotte, NC

• Responsible for federal tax matters involving planning, controversy, compliance and managing 3-6 tax professionals.
• Led project planning, due diligence, and implementation for acquisitions and divestitures, internal restructuring, and reorganizations under IRC sections 355 and 368
• Initiated efforts to begin claiming tax credit under IRC section 41 for increasing research activities, and led audit defense of credits claimed, leading to credits of more than $20M in each of the last three years
• Directed efforts to obtain private letter rulings on transactions to confirm non-taxable treatment, qualification for energy credit, and non-applicability of normalization provisions in accounting methods for repairs.
• Managed multiple audits in examination and appeals (most recently in the Pre-CAP program), as well as leading efforts to seek a pre-filing agreement to resolve tax issue involving a wind farm acquisition in order to.

Winston-Salem, NC

• Spearheaded establishment holding company structure along with contract manufacturing and commissionaire subsidiaries when company re-entered European markets in order to minimize activities and profits subject to.
• In-sourced preparation of U.S. transfer pricing reports for transactions < $50M saving the company more than $100k each year in fees for outside consultants.
• Successfully defended contract manufacturing and commissionaire arrangements established in 1990s by RJR Nabisco in Spain and Germany, and tax indemnity agreement issues with Philip Morris and Japan Tobacco avoiding.

Llm, Taxation

With Distinction

Bs, Accounting

Activities and Societies: Beta Alpha Psi

Jd, Law

Certificate In State Taxation, State Taxation

Ll.M, Taxation