Provided consulting services to clients for corporate and partnership restructuring to maximize the tax benefits in the
United States and foreign countries including international acquisition structuring and modeling of potential tax planning
▪ Provided consulting services to clients for merger & acquisition deals and advised clients on North America, Europe and
Asia Pacific tax issues which saved close to $100M for tax purposes.
▪ Reviewed US foreign filings including Form 5471, 5472, 8832, 8858, 8865, 926, 1120-F, 1116, 1118, 8992, 8993, FBAR,
K-2/K-3 for private equity firms with over $500 billion of asset under management
▪ Performed US/foreign outbound withholding analysis on foreign passive income tax treatment, REIT specific questions,
FIRPTA withholding issues and implications
▪ Associated multiple ASC 740 analysis documenting foreign withholding tax treatment issues, subpart F treatment of
company transactions and permanent establishment issues for multinational companies
▪ Constructed tax modeling to quantify the impact of GILTI, FDII, 199A PFIC and CTB election on foreign investments
▪ Facilitated tax training to junior staff on various triggering events of U.S. tax filing requirements and tax implications