Principal
Current• Conducted transfer pricing analysis and documentation studies for cross-border intercompany financial transactions including: guarantee fees (multinational pharmaceutical); a tax hybrid transaction (multinational pharmaceutical); acquisition loans (multinational cement / building materials company; multinational steel producer); global commodities trading book (multinational European bank); profit split and expense allocation (worldwide hedge fund distributor).• Determined… Show more • Conducted transfer pricing analysis and documentation studies for cross-border intercompany financial transactions including: guarantee fees (multinational pharmaceutical); a tax hybrid transaction (multinational pharmaceutical); acquisition loans (multinational cement / building materials company; multinational steel producer); global commodities trading book (multinational European bank); profit split and expense allocation (worldwide hedge fund distributor).• Determined stewardship and beneficial head office functions for global health insurer leading to charge out of beneficial U.S. head office service expenses to non-U.S. subsidiaries. These included actuarial, marketing, re-insurance, risk management, technology infrastructure, and treasury service expenses. Show less