Thomas Mooney Email & Phone Number

Boston, Ma, Us

Washington, District Of Columbia, Us

Us

Responsibilities include foreign derived intangible income (FDII), GILTI, Subpart F income, fixed assets, research and development tax credit, state apportionment, tax accounting and tax compliance. Employer is a global manufacturer and installer of undersea fiber optic cable.

Paris, Fr

Working with the internal audit group, audited processes and procedures of the tax department related to the Base Erosion Anti-Abuse Tax (BEAT). Issues included: (a) 1.882-5 foreign bank interest expense calculation and (b) transfer pricing.

New York, New York, Us

• Responsible for the computation of the tax provision (ASC 740) for all businesses and regions on a monthly basis. This includes quarterly earnings releases. Involves working with corporate controllers and planning & analysis (FP&A) personnel on presentations for CFOs/Controllers. Assist in 10K/10Q reporting. • For tax provision, involved in APB 23 calculation, tax advantaged income (low income housing tax credit, new markets tax credit, production tax credit) and computation of State & Local taxes - including NY Article 9A, Non-NY Unitary, Nexus Consolidated and Separate States• Manage Commercial Bank/Credit Cards global tax accounting group. Involves monthly tax reporting for approximately 2,000 subsidiaries in 100 countries. In addition to monthly tax provision, responsible for cash taxes paid, deferred tax asset rollforward and other comprehensive income (OCI) • Analyze implications of potential changes in U.S. tax law on corporate tax rate.• Develop tax structures that meet multi-year effective tax rate goals. Work with FP&A group. • Participate in Comprehensive Capital Analysis and Review (CCAR) (ie. Federal Reserve Stress Test) process by preparing consolidated tax computations for each risk scenario and evaluating deferred tax asset utilization. Involves working with Capital Planning Group. • In consultation with audit groups, calculate Commercial Bank’s federal tax contingency reserve balance (FIN 48).• Review corporate domestic tax returns

Frankfurt Am Main, Hessen, De

• Implemented tax reduction initiatives by making certain the company utilizes tax benefits such as NYS/NYC Article 9A investment income rules, NYS Zone Equivalent Area (ZEA) credit, New Markets Tax Credit and Research Credit. The Securities Finance department invested $120 million based on this tax advice and reduced NY Article 9A tax.• Responsible for Federal and State/Local corporate tax returns and tax provisions (ASC 740).• Oversee compliance with IRS and OECD transfer pricing rules. Initiated global transfer pricing studies and wrote transfer pricing agreements. Work with global tax department in implementing transfer pricing policy.• Advise Structured Product Group on withholding tax aspects of proposed transactions involving, for example, hedge funds, SPVs and equity derivatives. • Advise qualified intermediaries in six countries concerning U.S. Form 1042-S reporting and withholding rules. Worked with back office Operations department. Developed and implemented an internal audit program for Tokyo office. • Settle Federal, State and Local audits. In 2004, successfully settled NYS & NYC Article 9A corporate tax audits.

Responsible for tax issues for U.S. broker-dealer.

• Global tax manager responsible for all tax issues for international derivatives dealer with offices in five locations: New York, London, Tokyo, Hong Kong and Toronto. Includes ASC 740. • Work with outside legal counsel to negotiate and implement transfer pricing Advance Pricing Agreement (APA) between U.S. and U.K.• Responsible for the filing of corporate tax returns for all offices. This included foreign, federal and state/city returns in the US, UK, Japan, Hong Kong and Canada. • Successfully settled IRS, State & Local, and Japanese tax audits – involved issues such as Section 475 mark-to-market rules.• Advise traders on U.S. tax issues such as non-resident withholding tax. Also advised U.K. office on tax issues such as VAT partial exemption, manufactured dividend rules, and stamp duty reserve tax.

Montreal, Qc, Ca

• Responsible for federal and state/local corporate income tax returns. Issues included dividends received deduction, Leslie formula, state allocations and NYS/NYC investment income/expense. • Review Form 5471s for foreign subsidiaries in Europe and Asia. This included Subpart F and Earnings and Profits computations for each of the entities. Monitored intercompany loan activity and passive income to ensure compliance with Section 956 and PFIC rules.• Prepare Firm’s Section 482 transfer pricing documentation and coordinate monthly profit-split calculation with accounting department.• Provide tax advice to the Emerging Markets and International Operations departments concerning withholding tax on financial products in countries in the Pacific Rim, Europe, and Latin America. • Advise brokers and operations personnel on TEFRA tax reporting and withholding rules on Form 1099-DIV, Form 1099-INT, Form 1099-OID, Form 1099-B and Form 1042-S for financial products. Responsible for ensuring that Firm complies with IRS tax reporting, withholding and documentation rules. Specific areas of involvement include: reporting and withholding requirements for retirement products, commodities, mortgage-backed securities, and notional principal contracts; direct dealing with the Internal Revenue Service, including audit settlement responsibilities.

London, Gb

Masters, Taxation

Bs, Accounting