Responsible for global tax function for venture capital-backed startup software company with operations in the U.S., Canada, Europe and Asia
Part of successful 2012 IPO Team
Established transfer pricing, tax accounting and compliance systems
Review contract and sales/billing system for all tax matters including VAT, GST, and Sales taxes
Implemented ASC 740
Reorganized IP ownership
Member of Eloqua Executive Leadership Team

Responsible for global tax function-supervise staff and multiple outside consultants both in the U.S. and in-ternationally.
Responsible for successful completion of three year financial restatement initiated due to tax accounting is-sues raised by outside auditors with predecessor.
Implemented Fin 48 which required analysis of tax matters from 1996 forward.
Restructured German operations to isolate NOL’s in profitable Company in order to monetize them with disposition of Company.
Successfully completed German income tax audit involving transfer pricing issues.
Conducted in-house transfer pricing study for U.S.-Europe transactions as well as transactions within Europe.
Counsel of record in transfer pricing case of subsidiary –Intersport Fashions West v. United States (U.S. Court of Federal Claims).
Filed claims under special ten-year carryback rules for statutory liability losses resulting in significant re-funds.

Supervised staff of 5 professionals plus various dotted-line reports from shared service and overseas loca-tions.
Responsible for international tax planning all corporate, individual, and value-added taxes related to acqui-sitions, dispositions, and foreign sales activity ($6B annually in 40 countries).
Directed international aspects of IRS and foreign country audits, worldwide international compliance, Sar-banes-Oxley compliance and tax accounting (FAS 109).
Accomplishments included $3B privatization of Intelsat and favorable resolution of section 367 issues relat-ed thereto, $100M monetization of Inmarsat (UK) investment, utilization of $65M of expiring foreign tax credits, and successful completion of multi-year UK transfer-pricing audit.
Developed/defended positions for one of the largest FSC/ETI beneficiaries.




Special Items
Co-authored study on company’s international financial controls resulting in the reorganization of interna-tional finance function.
Represented company on coalition that worked with Congressional leadership to develop manufacturing exemption in 2004 Jobs Act.
Member of NFTC Working Group that led to creation of ETI deduction.
Received Lockheed Martin NOVA award (the Corporation's highest recognition), for outstanding perfor-mance in resolving IRS audit of $700M exposure related to acquisition/spin-off.
Directed project to reorganize expatriate function.

Supervised staff of 4 professionals.
Research and planning in all domestic/international areas.
Administered federal and state audits.
Directed in-house preparation of appeals (4 major appeals involved $100M in taxes and over 100 issues) of Counsel in federal and state litigation including industry-leading research tax credit case (Fairchild Indus-tries Inc. v. U.S., 71 F3d 868 (1995)).