Representative Projects

• Performed a transfer pricing project for a large U.S. based manufacturer which uncovered $30M of transfer pricing overpayments by the U.S. parent to its Canadian subsidiary. In addition, our team successfully negotiated retroactive cash refunds of prior related tax payments from Revenue Canada.
• Performed a transfer pricing project for a large U.S. based manufacturer which uncovered $30M of transfer pricing overpayments by the U.S. parent to its Canadian subsidiary.  In addition, our team successfully negotiated retroactive cash refunds of prior related tax payments from Revenue Canada.
• Served as lead tax advisor on the large asset purchase of a U.S. based multinational manufacturer.  As part of this project, discovered U.S. state incentives and credits for the buyer which effectively reduced the purchase price by over $30M.
• Served a lead tax advisor to the buyer on the purchase of a large U.S. S Corporation by a U.S. corporate purchaser.  Successfully constructed the purchase as an asset purchase which required guiding the private equity seller through a pre-sale reorganization.  As a result, the buyer acquired over $70M of tax deductible goodwill as part of the transaction.
• Performed a global supply chain review for a U.S. based technology manufacturer and identified and eliminated considerable U.S. Subpart F income without material legal entity or business operation disruptions.
• Advised a large German auto manufacturer on the sale of a wholly-owned U.S. dealer including guidance on Foreign Investment in Real Property Tax Act (FIRPTA) issues.
• Identified and collected over $10 Million in book and cash tax benefits related to both before and after a large bankruptcy filing for a large U.S. technology company.  These strategies permitted the company to report net cash tax income (rather than expense) for the first time in the company’s history.
• Created a global tax policy for a large U.S. based technology company that ensures compliance by finance team members around the world with tax, accounting, and legal rules and regulations of numerous U.S. and international jurisdictions as well as full compliance with Sarbanes Oxley 404 standards.
• Served as the lead tax advisor on over $1 billion in U.S. and international mergers & acquisitions.  This includes target analysis, due diligence, tax structuring, and purchase price negotiations.  Post-transaction activity includes tax department and systems integration, purchase accounting, and post-transaction tax structuring both within the U.S. and internationally.
• Developed a tax planning strategy to create a taxable loss for a U.S. domestic corporation that is a member of a large U.S. consolidated tax group.  The entire loss exceeded $100M and was recognized in the current year and was not subject to deferral even though the planning transaction took place entirely between related parties.
• Developed and implemented a proactive global transfer pricing policy for a large U.S specialty chemical manufacturer that delivered considerable tax savings while complying with both U.S. and international transfer pricing rules.  This project included both the restructuring of international legal entities as well as negotiating favorable tax rulings with foreign government tax officials.
• Designed and implemented a global tax reporting system which supports a global U.S. GAAP tax provision. This system allowed 124 global tax reporting locations, 88 of which are located outside the U.S., to perform a full U.S. GAAP close in 3 days. 
• Reviewed the compilation of global tax calculations supporting U.S. SEC reports 10K, 10Q, 8K, S4, and others as well as drafting the tax language used in these documents.  These calculations were subject to regular review by external Big Four auditors as well as the SEC and PCAOB.  All of these calculations and associated language have been correctly stated without exception.
• Developed and implemented a number of U.S. state tax planning strategies that encompasses income, property, sales, and use taxes. 
• Advised on over 100 export tax benefit projects featuring Foreign Sales Corporation (FSC) or Interest Charge Domestic Sales Corporation (IC-DISC) for U.S. based manufacturers and distributors that have resulted in over $30 million of tax savings.  This planning involved creating or optimizing export structures as well as the original calculation and recalculation of U.S. export tax benefits.
• Advised on Sarbanes-Oxley Section 404 design, documentation, implementation, and testing phases for a number of SEC registered publicly traded technology and manufacturing clients.  This includes serving as a resource to a number of SEC registered clients on various issues related to documentation and interpretation of Sarbanes-Oxley provisions.
• Assisted on a number of U.S. foreign tax credit planning projects which have increased a U.S. corporation’s ability to utilize existing foreign tax credits and mitigate or avoid a U.S. overall foreign loss (OFL).
• Advised on the initial structuring as well as the continued maintenance of a $4 billion U.S. based manufacturer’s global contract manufacturing / commissionaire structure featuring a Switzerland based principal corporation.  Some of the aspects reviewed and analyzed on a continuous basis included supply chain issues, transfer pricing, VAT, customs, as well as a number of U.S. and local foreign country tax issues.
• Advised on a global transfer pricing project for a $4 billion U.S. based multinational manufacturer.  This involved the coordination of a worldwide transfer pricing consulting team members as well as client operating personnel in the U.S., Europe, Asia, and South America.
• Advised on a number of transfer pricing projects for U.S. and European based multinational corporations with revenues ranging from $20 million to $4 billion.  In most projects, the global tax expense of the company was lowered while all applicable jurisdiction transfer pricing guidelines were met.
• Led tax due diligence and assisted in price negotiation on the acquisition of an India based manufacturer by a $10 billion U.S. tier one automotive manufacturer.  This included participating in client team meetings in both the U.S. and India to determine business strategies relative to this ongoing acquisition.
• Advised on a number of IRC §165 worthless stock deductions as well as IRC §166 worthless debt deductions in connection with capturing U.S. ordinary losses related to the liquidation of foreign subsidiaries. 
• Provided technical advice, design, and implementation of IRC §199 deductions for a number of U.S. manufacturers.
• Assisted on the acquisition of a Japanese multinational corporate group by a large U.S. based multinational retailer.  This included coordinating the efforts of tax professionals in the U.S., Japan, and the Netherlands in order to report to the client’s U.S. based global mergers and acquisition tax and treasury teams.  The tax issues addressed included U.S. federal, Japanese, financial services, transfer pricing, etc. 
• Led a supply chain restructuring for a U.S. based multinational manufacturer that included a global transfer pricing study as well as the U.S. and local country tax and legal issues related to introducing a principal / contract manufacturer / commissionaire strategy.
• Designed and implemented a foreign financial reporting system for a $1 billion U.S. based multinational manufacturer that significantly upgraded the financial and tax data available to the client’s U.S. tax group.  This allowed for greatly improved U.S. federal tax compliance reporting and recordkeeping as well as ease in obtaining data for future tax planning evaluation and implementation.
• Designed and implemented of a number of global transfer pricing plans for multinational corporations based both in the U.S. and abroad with a focus on global supply chain and principal / contract manufacturer / stripped distributor and commissionaire structures.   
• Designed and implemented the legal entity structuring as well as structured finance aspects of a $3B acquisition by a global automotive component manufacturer.  This resulted in significant U.S. tax savings as well as U.S. overall foreign loss (“OFL”) mitigation and cash repatriation benefits.
• Designed and implemented an IRC §861 expense allocation strategy for an $17 billion U.S. based global manufacturer across three related U.S. consolidated tax groups. This strategy greatly increased the company’s ability to use existing foreign tax credits. This strategy involved creating a human resources strategy to motivate and compensating the client’s operating personnel to dedicate considerable time to helping complete a significant tax-based project.
• Designed and implemented a foreign tax credit attribute, management fee, and royalty study for a $2B global medical equipment manufacturer.  This greatly increased the ability to use existing foreign tax credits and increased global cash flow.
• Designed and implemented a number of IRC §165 worthless share deductions for foreign subsidiaries of a number of U.S. and foreign based corporations.  This resulted in creating U.S. tax losses in excess of $100 million.
• Advised on U.S. and Mexican international tax issues related to restructuring the $1B U.S. operations of a $5B Mexico based multinational steel manufacturer.
• Assisted in the structuring and design of the India operations for a $41 billion U.S. based multinational computer equipment manufacturer.