Thomas Helton, Cpa, J.D., Ll.M., Taxation Email & Phone Number

Arlington, Virginia, Us

Arlington, Virginia, Us

Mclean, Va, Us

Manage global provision, SEC reporting, compliance and planning. Responsible for global transfer pricing policy and compliance. Co-developed with third party tax advisors an alternative transfer pricing methodology that balanced the US, the foreign jurisdiction and the business case requirements. Mitigated capital loss carryforward resulting in a substantial reduction in the amount of future capital losses that would have otherwise been generated and would have expired unused. Teamed with accounting, cash management and legal to develop a tax efficient method to move cash between and among the global affiliated group. Coordinate and manage third party tax advisors in connection with the R&D study, transfer pricing, SALT, US and non-US compliance, planning and general consulting. Review proposed transaction documents. Draft and review tax technical memoranda. Monitor, analyze and document effects of new federal, state and non-US tax law. Develop and train staff.

Santa Clara, California, Us

Provided a wide range of partnership and corporate consulting services including drafting complex technical memoranda (e.g. tax consequences of debt restructuring and technical terminations of partnerships triggered by deemed Code section 332 liquidations); researched issues related to proposed transactions; prepared annual and quarterly tax provisions. Developed special forms and disclosure requirements inventory triggered by acquisition. Drafted FIN 48 and VA memoranda. Reviewed federal partnership, consolidated and separate company state tax returns. Special projects included drafting state VDA requests, preparing tax basis balance sheets, modeling tax effects of proposed transactions, and developing work plans. Trained staff.

Santa Clara, California, Us

Provided a wide range of partnership and corporate consulting services including drafting complex technical memoranda (e.g. tax consequences of debt restructuring and technical terminations of partnerships triggered by deemed Code section 332 liquidations); researched issues related to proposed transactions; prepared annual and quarterly tax provisions. Developed special forms and disclosure requirements inventory triggered by acquisition. Drafted FIN 48 and VA memoranda. Reviewed federal partnership, consolidated and separate company state tax returns. Special projects included drafting state VDA requests, preparing tax basis balance sheets, modeling tax effects of proposed transactions, and developing work plans. Trained staff.

Tax advisor and client relationship executive for multi-national clients requiring a broad federal, state and international tax technical base. Mitigated a multi-national’s section 956 inclusion by providing alternatives to its cash management practices. Proposed entity rationalization. Planned and managed a staff of 20 professionals in connection with the compliance process for multi-national corporation that included 64 Forms 5471 and Forms 8858. Reviewed transaction documents, drafted statements and special forms associated with cross-border acquisitions. Drafted and reviewed tax memoranda addressing a wide range of federal, state and international tax issues. Technical reviewer for complex multi-national compliance and provision review engagements. Developed business. Trained and mentored staff.

London, Gb

Senior executive tax technical lead responsible for planning, managing and delivering tax compliance and provision assessment and tax technology tool implementation engagements. Facilitated discussions between accounting and tax functions to identify, evaluate and collect data points to be used during assessment, design and implementation phases of the consulting engagement. Responsible for understanding clients’ organizational structures, transactions, data flows and accounting. Client relationship executive responsible for maintaining and growing client relationships.

Special tax counsel for litigation team in Zurich, Switzerland managing professionals, reviewing work product and assessing tax risk associated with certain legal structures under US tax principles; US tax technical resource and project manager for the Swiss bank; managed 3 other service providers, trained and supervised junior associates and 8 contract attorneys. Drafted memoranda and tax opinions related to securitizations, reorganizations and global information reporting.

London, Gb

Tax lead for more than 250 cross-border derivative transactions on leased property: performed due diligence, developed structures, drafted transaction documents with third party legal counsel, reviewed and validated financial models, managed closing processes and drafted related tax opinions and supporting memoranda. Drafted tax opinions related to securitizations, cross-border leasing arrangements, and other leasing transactions. Developed reconciliation process between and among a client’s tax compliance database, its leveraged lease runs and its deferred tax inventory related to its cross-border aircraft leasing portfolio. Reviewed leasing companies’ tax provisions. Managed, reviewed and drafted IDR responses and appeals protests in connection with cross-border lease transactions for numerous financial institutions. Developed structural schematics to educate a client regarding the legal structure, the tax structure, defeasance, and cash flow of its cross-border leasing transactions.

Performed research and drafted tax opinions, memoranda, letter ruling requests, responses to IRS inquiries and appeals protests related to a variety of tax issues including the spin-off of electric utility generation assets, securitizations, and structured financial transactions.

Researched and drafted memoranda to support tax accounting for transactions or to support tax return positions. Managed all tax compliance for the consolidated group and numerous separate reporting entities including partnerships and trusts. Responded to IDR’s during annual IRS audit. Reviewed tax related financial disclosures for S.E.C. reporting. Implemented CORPTAX, customizing the software to produce the consolidated tax provision.

London, Gb

Prepared federal and state tax returns for corporations, syndicated real estate partnerships, and tax-exempt entities. Reviewed client prepared tax provisions. Drafted supporting memoranda for tax return reporting positions.

Ll.M., Taxation

J.D., Law

B.S, Finance