Samuel C. Email & Phone Number

Us

Worldwide, Oo

● Represented private equity firms and large corporations as buyers and sellers in US and non-US stock purchases, asset purchases, and mergers up to $7 billion. Representation included performing tax due diligence, modeling and quantifying tax risks and opportunities, developing sale and purchase agreement negotiating positions, structuring acquisitions and dispositions, and providing post-deal integration advisory.● Represented financially challenged companies with turnaround and restructuring services, including analyzing relevant tax issues and financial considerations, evaluating restructuring options, and building a framework that allows for future tax and operational efficiencies.

Gb

● Advised multinational enterprises on structuring new, and restructuring existing, intercompany transactions and entity structures in order to minimize tax leakage and create operational efficiencies as a result of the Tax Cuts and Jobs Act.● Performed financial transaction analyses in connection with mergers, acquisitions, and restructurings that consisted of estimating an entity’s maximum amount of serviceable debt, estimating the appropriate interest rate to be assigned to new indebtedness based on creditworthiness analyses, reviewing loan agreements for contractual terms to support debt classification treatment from an IRC 385 perspective, and modeling the impact of IRC 163(j) on business interest expense deductions. ● Prepared IRC 482 and non-US transfer pricing compliance documentation (e.g., local files, master files, and country-by-country reports).● Performed other ad hoc services that included tax audit support, tax valuations for intercompany tangible and intangible assets transfers, transfer pricing controversy and dispute resolution, and transfer pricing due diligence and post-deal integration for mergers and acquisitions.

Notre Dame, In, Us

● Managed a live ~$12M long-only equity portfolio of the university’s endowment that included analyzing information and trends in the global economy, being the subject matter expert for information technology sector, reviewing the portfolio’s structure for adherence to risk management benchmarks, and presenting investment recommendations and key portfolio risks to the university’s investment board. ● Performed company background analyses, fundamental analyses, EPS forecasts, beta estimations, technical analyses, free cash flow valuations, and multiples valuations reports for the portfolio’s holdings in Alphabet and Facebook.

● Represented clients in Knox County General Sessions Court and Knox Country Juvenile Court, having all charges dropped.● Represented a client in a juvenile asylum case before the Memphis Immigration Court who was granted refugee status.● Performed legal research, interviewed clients and witnesses, drafted motions and memos, and negotiated plea deals.

Master Of Laws - Llm, Tax Law/Taxation

Master Of Business Administration - Mba, Finance, General

Doctor Of Law - Jd, Law

Bachelor Of Business Administration - Bba, Business Administration And Management, General

Bachelor Of Science - Bs, Finance, General

Associate Of Science - As, Finance, General