Sr. Tax Counsel, Global Planning & Strategy (after having been Sr. Tax Advisor for Downstream / Trading), where I was Shell’s U.S. tax advisor for Wind, Solar and related Energy projects. Worked extensively with the tax, financial and management teams of this large multinational conglomerate. (Also a Director for various Shell subsidiary companies). Responsible for international & domestic research and planning, including issues arising from federal and international tax audits. Handled corporate mergers, acquisitions, divestitures, spin-offs, including Affiliated Groups and Deconsolidations. Heavily involved with international tax matters in countries throughout the world, including transfer pricing, foreign tax credits, Participation Exemptions, Permanent Establishments and Treaty interpretation issues. (E.G., utilized Caribbean Tax Treaty network and Barbados – Dutch Treaty to eliminate Withholding taxes for a regional LNG project). Ensured that intercompany agreements and studies supported arms-length prices charged in intercompany transactions in accordance with OECD and US tax standards. Involved with preparation of Transfer Pricing Reports. Reviewed proposed tax law changes that could affect the Company, and participated with API, OECD, and others in drafting comments and proposed changes. Met with House Ways & Means Committee, Senate Finance Staff, and the Joint Committee on Taxation to discuss the Camp, Enzi and Bachus Tax / Subpart F proposals.

Provided legal & tax services, including M & A and related due diligence work, to closely held and public companies and high net worth individuals, foreign and domestic. Worked in Corporate, Partnership, LLC, individual income tax, Alternative Minimum Tax and estate tax & succession planning, deferred compensation and retirement and 401(K) plans. This includes comprehensive tax planning / consulting work that produces detailed tax plans and illustrations. The tax issues have included section 482 allocations, intercorporate and transfer pricing, NOL carryforwards, Subchapters C & K topics, sec. 368 Reorgs, Tax Treaty interpretation, and other areas of global tax minimization. Restructured foreign operations into Qualified Treaty entities to qualify dividends for the U.S. 15% (now 20%) QFD tax rates, instead of the ordinary income rates. As an expert in Subpart F, I have restructured certain CFC’s companies to avoid shareholder taxation of undistributed corporate earnings, while operating free of U.S. and other corporate income tax pursuant to IRC sec 883. Worked with Inbound and Outbound transfers, section 367, Treaty Interpretation, Foreign Tax Credits (direct, indirect, and “in lieu” of credits), and basket / limitation issues.

Worked on domestic and international tax issues, joint ventures, tax disputes, foreign tax credits (direct, indirect), interest allocations, transfer pricing, partnerships, financings, acquisitions, sales, section 1031 exchanges, farm outs & ins. Dealt with IRS IDR's, Alt. Min. Tax, & other audit and FAS 109 dfd. tax issues. Rebutted IRS arguments that billions of dollars of taxes paid under Production Sharing Contracts did not qualify for the U.S. FTC’s. Received award from the Board of Directors for structuring 1st Japanese entity majority owned by a U.S. company to obtain Japanese Government funding for investment outside Japan, via a corporation minority owned by Russian, Vietnamese, and Japanese entities. (All dividends were fully covered by FTC’s). Assisted Vietnamese government in revising its business laws; was in Hanoi the day the U.S. Embargo was lifted. Conducted worldwide study re use of Proportionate Profits Method for sec. 907 FOGEI/FORI limitations. Represented Mobil on Prudhoe Bay Tax Comm., was involved in Dismantlement & Restoration cost deduction and other issues. Involved with investment and transmission projects set up as partnerships with state oil companies and other corps. in South America, Asia, Africa, and the mid East (e.g., upstream & downstream Qatargas & Ras Laffan entities), and also sec. 936 Possessions Tax Credit.

Florida based International Tax, Corporate, Energy & Maritime practice. Advises public and privately held companies in areas such as Outbound Transactional Structuring and Subpart F, Inbound Transactions, Check the Box Principles, U.S. Tax Treaty utilization, Repatriation Strategies, Intangible Property Planning, Structured Finance, Base Shifting, Foreign Tax Credits, Transfer Pricing, Mergers, Acquisitions & Corporate restructurings, private equity and venture capital, cross-border transactions and general corporate matters. Prepares FINCEN Form 114 and other Foreign Bank Account Reports (FBAR). Represents taxpayers re federal and state tax audits and appeals, as well as Private Letter Rulings. Advisor to Shipping Companies concerning the set up and tax free operations of International Shipping Income, Bareboat & Time Charters, Concessionaire and other Agreements. Experienced in State & Local Tax planning & compliance, and Estate & Gift Taxation and Planning.