Perform tax due diligence of target companies in various industries and identify tax risks in transactions.
Review M&A agreements and provide tax comments based on due diligence findings.
Prepare models on key tax issues such as thin capitalization, cash tax projection, AHYDO implication, attribute reduction, basis step-up, etc.
Write tax memoranda on NOL limitation, inversion transaction, the consolidated group rules and financial instruments (OID, COD income, Section 163(l)).
Provide advice on tax efficient acquisition structures relating to entity formation/liquidation, US tax elections, treaty benefit and reduction of tax leakage on intercompany payments, and future exit strategies.
Support engagement leaders on various project as acting manager.
Tax Associate, 03/2012 - 06/2012 Jun He Law Offices – City, STATE,
Prepared tax analysis for local and international tax planning and business initiatives. Prepared tax memorandums and other written advices for PRC tax issues. Supported corporate legal teams from PRC tax perspective.
M&A Tax Associate, 09/2010 - 03/2012 PwC China – City, STATE,
Performed tax due diligence reviews in M&A transactions in various industries and identified PRC tax exposures.
Advised on foreign direct investment related tax issues in China.
Advised on PRC customs and cross border payment issues.
Qualifications
New York State CPA
PRC Bar
IRS Enrolled Agent
Education
L.L.M: International Taxation, Expected in 2013 - University of Florida - Gainesville, FL GPA:
Research Assistant to Prof. Michael Friel
Bachelor: Law, Expected in 2010 - Beijing Foreign Studies University - Beijing, GPA:
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