• Manage global transfer pricing for $40B company
• Coordinate and oversee transfer pricing efforts of worldwide team located in three poles.
• Structure and plan cross border transactions to be compliant with local and international laws.
• Supply chain structuring in tax efficient and cost effective manner to include Permanent Establishment avoidance, VAT and customs exposures, and maximize profits.
• Analysis and calculation of FIN48 issues and supporting documentation
• Lead and coordinate efforts in the defense of global transfer pricing and cross-border tax audits.

• Identified issues and implemented strategies while serving on Dell’s Transfer Pricing Counsel core team. Results will bring more efficiency and accuracy to global transfer pricing initiatives.
• Advised foreign affiliates, and prepared documentation to facilitate negotiations of Advanced Pricing Agreements with Australia, Japan, and China.
• Coordinated the preparation of global transfer pricing documentation and reviewed all positions for consistency.
• Prepared responses to Information Document Requests from both U.S. and foreign governments, related to global transfer pricing positions and intercompany dealings.
• Assisted and advised on the structure and core training of the Dell transfer pricing center of excellence located in Bratislava, Slovakia.

General Electric Company (Corporate), Albany, NY
Senior Tax Manager – Tax Controversies
• Analyze and prepare audit defense strategies in support of international and domestic tax positions.
• Member of the GE Transfer Pricing Counsel; served as lead in a number of corporate tax initiatives.
• Corporate Tax Controversy lead in preparing defense for transfer pricing Tier I issues: §1.482-7 Cost Sharing, §367(d) intangible transfers, and §936 exit strategies.
• Advise General Electric Company businesses on the implementation and defense of complicated issues related to Foreign Tax Credit planning and foreign source income.
• Consultant to General Electric Company operating divisions regarding business tax planning initiatives.
• Lead liaison between General Electric Company and the IRS in reconciling tax adjustments for open tax years.
• Subject matter expert in the design and implementation of internally developed transfer pricing software.

10/99 – 02/05 General Electric Company (Consumer & Industrial), Plainville, CT
Transfer Pricing Manager
• Responsible for the planning and documentation of transfer pricing policies for multinational business with over 200 foreign affiliates.
• Managed the defense of foreign transfer pricing audits and served as the point of contact for taxing jurisdictions.
• Assisted in the preparation of domestic and foreign tax submissions within General Electric Companies compliance reporting systems.
• Responsible for the implementation o

• Prepared and filed federal consolidated tax return and all state income/franchise tax returns.
• Advised on and monitored international “doing business” issues.
• Planned and advised on the restructuring of international operations.
• Supervised the preparation of sales, use and property tax returns.

• Researched restructuring and merger transactions for state and local tax minimization.
• Analyzed provisions for income taxes in accordance with FAS 109.
• Prepared and reviewed Federal and State consolidated and multistate tax returns.

• Served on Mediterranean contingency force during German reunification (Fall of Berlin Wall)
• Member of Multinational force providing security for the 1989 Malta Summit.
• Worked closely with high ranking officers/officials on cross-training initiatives between U.S. and NATO forces.
• Veteran of Foreign War (Desert Storm 1990 – 1991)