Palo Alto, California, United States
Manage appeals and litigation relating to tax matters in US and foreign jurisdictions.
Manage international tax and controversy projects. Research and prepare planning slide decks, technical memoranda, and advocacy papers.
• Advise multinationals on Transfer Pricing strategy; prepare Transfer Pricing documentation; draft submissions for unilateral and bilateral APAs and Competent Authority requests. • Represent clients who are facing audits and appeals, most notably in connection with international transactions and the development and use of intellectual property. • Experience with eCommerce, online advertising, social media, software, and semiconductor businesses. • Manage and coordinate factual development, economic analysis, legal research and drafting for diverse projects.
• Advised multinationals on cross-border tax issues related to cross-border M&A, Subpart F, FTC, U.S. trade or business, ECI, PE, and Tax Treaties. • Managed multiple client engagement teams while maintaining effective communication with clients to ensure client satisfaction. • Actively contributed to business development, knowledge bank, and lead periodic department seminars on recent tax law developments. • Oversaw associate work and development in connection with diverse range of projects.
• Researched and prepared memoranda on diverse tax matters. • Represented clients at various stages of tax controversy and litigation.