• Researched and documented tax technical positions relating to corporate restructuring and other tax planning efforts• Extensive involvement with advocacy, review, and implementation of the Tax Cuts and Jobs Act• Assessed tax implications and recommended tax-efficient planning and structuring strategies related to US M&A• Worked with the global tax accounting team to support and document US tax positions• Provided strategic analysis and support for US federal and State Tax audits

• Manage all US and foreign taxation issues related to the Americas region for the PayPal business unit of eBay, Inc. and coordinate among various corporate groups such as legal, accounting and treasury and groups within the tax department including provision, compliance and transfer pricing• Analyze and implement effective corporate structures for all mergers and acquisitions, global expansion and new products to minimize tax exposure and risk and reduce US and foreign taxes• Research and document tax positions connected to restructuring and acquisitions, including FIN 48/ASC 740 documentation related to issues such as Subpart F, Permanent Establishment, Foreign Withholding Taxes, and Section 956 • Review and negotiate tax clauses in various commercial agreements• Maintain in depth involvement with tax issues related to operations in Brazil including corporate and intellectual property restructurings and analysis of direct and indirect taxes

Manager, International Tax Services, 2003 to 2008; October 2010 to August 2011• Researched, developed and documented client strategy on issues such as Subpart F, formation of corporate entities, US withholding requirements, US effectively connected income, PFIC’s, use of branches and hybrid entities and instruments, offshore intellectual property structures, and mergers and liquidations of foreign entities• Prepared and reviewed tax provision calculations and footnote disclosures for various publicly traded and privately held companies• Managed teams of Deloitte Tax staff on complex compliance engagements for companies in the high-tech, software, bio-tech, retail, private equity and real estate industriesManager, International Tax Ideas & Solutions, London UK, October 2008 to July 2010• Managed the firm’s global database of cross-border tax planning ideas and solutions through the culling of existing ideas for relevancy and accuracy, the creation of new ideas and the application of ideas to various client situations and jurisdictions