Renato C. Email & Phone Number

Atlanta, Ga, Us

• Lead global TP policy and compliance (TP studies, Masterfile, CbCR), and strategy during startup's international expansion.• Drive international income tax, indirect tax and transfer pricing for metaverse, realty and technology business collaborating with finance, legal, HR, and operations. • Structure tax optimized arrangements with third parties, review tax treaties and conduct permanent establishment analysis.• Manage strategy around legal entity structure, funding options, plans for future repatriation of cash and withholding tax.• Review tax provision for foreign affiliates, including identifying local GAAP to US GAAP differences, and reconciling deferred balances on local ledgers. • Assist with consolidated global tax provision under ASC740, and prepare supporting workpapers for international operations, including forms 5471, 8865, 8991-BEAT, 8992-GILTI, Subpart F, and E&P.• Manage various advisors supporting the organization with US and foreign tax obligations.• Establish cross-departmental processes to improve reporting and accounting for international tax and transfer pricing.• Partner with internal teams on M&A activity to ensure proper due diligence and integration into the organization.• Monitor global legislative tax developments to communicate to leadership and ensure company is positioned to comply, including BEPS 2.0 Pillar I and II quantitative modeling and planning.• Continuously evaluate legal entity, transfer pricing and operational structure to identify potential tax savings.• Assist with day-to-day operational tax department responsibilities as it relates to leading a completely virtual team.

Atlanta, Ga, Us

• Led global TP policy, strategy and planning, controversy, controls, and compliance, including notifications/CbCR and preparation of 150 TP studies globally spanning 8 business units with decentralized operating models.• Established valuations process and partnered with external service provider for the completion of IP and legal entity valuations.• Partnered with Federal Tax Director on controversy matters and led TP components of controversy, including analysis of positions, modeling results, collaborating with external legal firms, filing of MAPs and participating in IRS opening conferences and appeals meetings.• Reviewed operating margin of legal entities on a quarterly basis to comply with TP principles/benchmarks; and partnered with tax reporting team to leverage this process for tax forecasting purposes.• Drafted various types of intercompany agreements and created centralized intercompany agreement repository.• Reviewed intercompany structures and intellectual property across the globe and proposed solutions that consolidate functions, reduce legal entities, and simplify TP structure while reducing intercompany accounting complexity.• Presented supply chains and transfer pricing to senior leadership and other groups (customs, legal, international tax etc.) across the organization to educate and drive synergies.• Partnered with Customs, International Tax, State Tax, Accounting, Legal, Treasury, and operations to execute tax planning projects, including cash repatriation, TP adjustments and process improvements around international tax reporting.• Monitored legislative changes globally (BEPS/OECD/local etc.) and modeled impact. • Managed team of 2 TP professionals, various in country resources and external service providers.• Partnered with tax leadership to create culture of collaboration, increase transparency within tax and explore automation. • Revived global ERG to help drive diversity, equity, and inclusion initiatives for the organization.

New York, Ny, Us

• Responsible for global TP compliance, policy and planning working with external consultants and non-US tax teams.• Developed TP models to evaluate changes in pricing and their impact on financial forecasts.• Collaborated with international accounting and technology teams to automate intercompany arrangements.• Monitored and reviewed results of global intercompany transactions on a quarterly basis.• Led discussions with executives on TP concepts, supply chain, strategy, results, planning, and process improvements.• Monitored BEPS/OECD legislative developments and liaise with international controllers to comply with CbC reporting.• Built and fostered relationships with service providers and business executives domestically and internationally.• Reviewed TP controls and managed testing of controls on an annual basis• Managed TP budget of approximately 1M for departmental forecasting purposes.• Partnered with M&A and tax counsel on integration of newly acquired companies and ensured proper due diligence.• Reviewed all payments to foreign vendors to ensure compliance with Sec. 1441 and reviewed withholding tax returns. • Managed recovery of VAT on travel by U.S. employees to Europe and advised businesses of VAT implications.• Reviewed provision of CFCs and branches, reconciled balance sheet tax accounts for review by Chief Accounting Officer. • Partnered with Head of Tax Compliance in review of applicability of Subpart F• Reviewed Form 5471s for alignment with tested transactions on transfer pricing studies.• Partner with external service providers to monitor global tax compliance status and audits.• Advise international tax operations on mobility of employees, permanent establishment and reporting.• Partner with Treasury and operations on dividend/cash repatriation efforts.• Led RFPs for global TP documentation, global tax compliance and accounting services in 25+ countries.

New York, Ny, Us

New York, Ny, Us

New York, Ny, Us

• Prepared transfer pricing reports in line with Sec. 482 of the Internal Revenue Code.• Corresponded and maintained relationships with global corporate clients.• Performed functional interviews and met with global clients to understand their business, structure, transfer pricing and supply chain.• Discussed strategy regarding global supply chain structuring, global transfer pricing modeling and relative tax implications.• Developed dynamic transfer pricing models for clients that facilitated jurisdictional projections of taxable income and tax expense.• Coordinated with KPMG member firms in other countries to facilitate completion of large global projects.• Researched transfer pricing and tax regulations.• Reviewed clients’ financials to ensure transfer pricing implications were accurately addressed.• Corresponded with Internal Revenue Service to negotiate positions on Advanced Pricing Agreements (APA).• Performed quantitative and qualitative analyses as part of benchmark searches for comparable companies and/or agreements relevant to transfer pricing analyses.

Munich, De

• Prepared transfer pricing documentation and analysis of financial data to support the arm's length nature of foreign affiliate transactions.• Prepared short memoranda and financial analyses summarizing the Siemens business models, transfer pricing arrangements in place and financial results. • Complied with transfer pricing documentation requirements to facilitate transfer pricing audit defense. • Coordinated and participated in transfer pricing interviews and planning calls with Industry sector businesses and their executive management to ensure appropriate transfer pricing methodologies were in place.• Managed relationship with outside service provider to facilitate the transfer pricing process.

Munich, De

• Prepared complex federal, international, and state tax returns for multimillion dollar legal entities. • Prepared monthly income tax provision in adherence with FAS 109. • Interacted with external auditors on a quarterly basis to clarify tax provision and address questions.• Reconciled deferred taxes to balance sheet to ascertain accuracy of balance sheets. • Managed tax compliance software, e-filing process; coordinated mapping of chart of accounts, adjustments and legal entity structure; including integration of newly acquired entities.• Trained other team members with software strategies and processes. • Led consolidation of Siemens USA tax return and resolved various consolidation issues in conjunction with Director of Tax Compliance. • Interacted with business units to gather proper documentation and support for intricate transactions.• Calculated tax basis on sales of business units to determine tax gain/loss along with preparation of purchase price allocation.• Computed deferred tax carve out of divestitures/transfers.• Coordinated integration of newly acquired companies from a tax perspective.• Reviewed affiliate’s tax provision and provided advice on tax treatment of transactions. • Reconciled balance sheet tax accounts on a monthly basis. • Gathered data for purposes of DPA/Sec. 199 Deduction, 1042 reporting, Transfer Pricing, Federal State & City tax packages and IRS information document requests. • Coordinated value added tax (VAT) efforts to ensure proper payment and/or refund from European taxing authorities. • Provided business units with general tax advice as it pertains to income tax, VAT, international tax (permanent establishments), and sales tax. • Researched new tax legislation• Tested Sarbanes Oxley internal controls of various accounting departments. • Reviewed cost center monthly activity against yearly budget. • Participated in forensic audit project with the Corporate Finance Audit group of Siemens Corporation.

M.S., Accounting

Bachelor Of Science, International Business