Tax Director Resume Example

• Successfully concluded a huge Sec. 861 expense allocation project that required much research, analysis and documenting the results for positions taken that would be supportable under audit.
• Instrumental in the completion of a complex Overall Foreign Loss (OFL)/Overall Domestic Loss (ODL) interplay involving CFC netting, and recharacterization of foreign and US income coovering 12 year period with cost savings of >$1M. 
• Worked with the competant authority group in DC, the IRS  and the CRA on transfer pricing issue and successfully concluded the audit for the years 2001-2006 through the 2011 audit cycle with no adjustment and tax savings of >$2M.
• Assisted counsel with the implementation of the Dutch restructuring to eliminate holding companies no longer required and optimized existing structure to align with business needs and vision. 
• Favorably resolved open audit issues and closed local examinations in record time and built good relations with foreign country tax examiners in Europe, Canada and Latin America.  

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• Documented procedures, identified areas to improve internal controls and gain additional efficiencies and implemented policy changes in local countries.
• Undertook the analysis and documentation of capitalizing vs. deducting transaction costs related to acquisitions and dispositions.
• Initiated and oversaw the successfull refinancing of loans between the various Dutchcos thus eliminating the annually trapped unused $2.5M wihholding tax.

• Responsible for all aspects of international tax including the coordinaion and supervision of tax compliance, tax accounting, tax audit, cash repatriation, Subpart F income and foreign tax credit planning, E&P study, Sec. 987 & 988 impacts, R&D credit analysis and Sec. 861 expense allocation analysis.
• Other responsibilities included overseeing the Transfer Pricing study and handling cross-border related PE issues.
• Documented procedures, identified areas to improve internal controls and gain additional efficiencies and implemented policy changes.
• Re-engineered the interest expense, R&D, SG&A computations and documented positions taken that would be supportable under audit.
• Assisted with local country audits and ensured minimal or no adjustments resulted from tax examinations.
• Monitored compliance with local country generally accepted accounting principles and company procedures and FIN48 reserves needed for local country positions taken.

• Performed tax consulting and loan staff services for multi-nationals like General Electric, GE Capital, Hewlett Packard, Ingersoll-Rand, Texaco, Xerox etc.
• Managed projects and coordinated year-end provisions, tax compliance and audits for large multi-national clients with operations in Canada, Europe, the UK, South America and Asia.  
• Responsibilities included shoring up information on entities through recent acquisitions, reviewing local country returns, compiling data on audit status in the various jurisdictions, foreign tax credit calculations, assisting with tax compliance, implementing new tax software and providing training to use the tax software.