[Fredslist] International Tax Expert Next Opportunity

[Monica kaufman]

Hi everyone…


My husband Jeff is looking for his next opportunity…. Please help.

He has over 20 years professional experience and is an expert in International Tax and Transfer Pricing.  


Below you will find his resume

His personal email is : Jbriankaufman at Hotmail.com

His Cell Phone: 610.306,4187


JEFFREY KAUFMAN

8004 Brasstown Drive, McKinney Texas, 75070

610-306-4187 (C) – jbriankaufman at hotmail.com

 

 
International Tax Leader 

Transfer Pricing Specialist

 

KEY INDUTRIES SUPPORTED:





 
 
 
Technology

Software

Pharma

Bio-Tech

MedDevices/Supplies

Retail

ConsumerGoods


FinServices

Manufact/Distrib.

Utilities

OilIEnergy

SupplyChain/TESCM

Auto

Agriculture


 

 




 

 

KEY TRANSFER PRICING FUNCTIONALEXPERTISE:

 
 
Planning

Controversy/DisputeResolutions

CostSharingAgreements

M&A


Compliance

IRSAudi tDefense

CompetentAuthority

Restructuring


Documentation

IRSAppeals

IP/Intangibles

DueDiligence


Valuations

APAExperience

Tangibles

Licensing


 

                                                                                                                  

 
PROFESSIONAL EXPERIENCE

 

Ryan, LLC, Dallas, Texas, 2011 – Present

 

Director, Transfer Pricing, International Income Tax Practice

First Transfer Pricing Director at Ryan; Introduced transfer pricing service line for Ryan:

Manages and directs transfer pricing projects for multinational firms.  


Experienced with global tax management initiatives, cost allocation models, IP migration projects, documentation for client transfer prices, and compliance with government regulations.  


Familiar with U.S. Treasury Regulations Section 482, OECD, Pan-European and Pan-Asian transfer pricing regulations. 



Developed spreadsheet based affiliate risk calculator to credit score and estimate risk premium for affiliates in a multinational company.


Developed spreadsheet based transfer pricing valuation model for gold mining projects


Helped save Canadian client over $1 million in assessed taxes in CRA audit.


Developed BEPS analysis tool for Ryan transfer pricing practice.


Business Development :


Conducted assessments of existing client base and identified additional service offerings to generate revenue.

Leveraged existing client base to win engagements with firms in the gold mining and agricultural products markets.



Successful team efforts to obtain new transfer pricing client for the firm.

Responsible for the development of Ryan’s transfer pricing services LOB in the international income tax practice. Earned a million dollars in revenue in 2 years.


Won engagements with Canadian firms in woodtaping, bearings and software industries


Won engagements with Austrian firms in metals and aerospace components markets.



 

McGladrey, New York, NY, 2007 – 2008; Phoenix, AZ 2008 - 2011

 

Director – International Tax; Transfer Pricing

Manage and direct transfer pricing projects for multinational firms; 

prepare and defend rebuttal reports to IRS issued economic transfer pricing studies; 


prepare responses to IRS and foreign tax authority IDRs; 
grow new engagements from existing clients; solicit business from new clients; 



write articles on transfer pricing issues; 


coordinate transfer pricing analysis within broader global tax management initiatives; 


develop cost allocation models; document client transfer prices for compliance with government regulations; 


help prepare companywide response to new 6694 tax preparer regulations  as it relates to transfer pricing, instruct transfer pricing seminars and webcasts. 


 

            Expert Reports and Rebuttal Reports

On behalf of eyeglass frame taxpayer prepared rebuttal to IRS economist report by merging economic theories of market entry with the arm’s-length principle to justify use of a profit split and rejects the IRS proposed tax adjustment.

 

            Information Document Requests

Responded to IDRs from the U.S. IRS, Canadian CRA, and the Australian ATO; IDRs covered companies in manufacturing, distribution and industrial markets

 

Business Development

Conducted assessments of existing client base and identified additional service offerings to generate revenue.


Existing clients for whom I have won multiple engagements:

International Telecommunications Company in China


Enterprise Management Software Company in New York City


Magnetic Technologies Company in Rochester, New York


Automobile Wheel Alignment Testing Machine Manufacturer in Akron, Ohio


School Bus Service Provider in New Jersey


Government Lobbyist and Public Relations Firm in Washington, DC


Optical Communications Equipment Manufacturer in Southern California


Wrist Watch Manufacturer in Reno, Nevada


Value Added Distributor of Executive  Aircraft in New Jersey


 

Lead team efforts to obtain new transfer pricing client for the firm.


New client acquisition

Steel Tube Manufacturer for Automobile Airbags in Las Vegas, Nevada


Enterprise Management Software Company in New York City


Contributed to team efforts to obtain new transfer pricing client for the firm.

Cigarette Manufacturer from Paraguay


Book and Movie Club Retailer in New York City


Wrist Watch Manufacturer in Reno, Nevada



 

Thompson Reuters/CrossBorder Solutions, New York, NY, 2006 – 2007

 

Senior Manager-Transfer Pricing

Managed a team of nine transfer pricing specialists to produce transfer pricing compliance and planning documentation, which covered a diverse set of industries including high technology, software, insurance, finance and pharmaceuticals.  


Completed the review and analysis of over 500 intercompany transactions during calendar year 2006.  


Business Development :

Conducted assessments of existing client base and identified additional service offerings to generate revenue.


Lead team efforts to obtain new transfer pricing client for the firm.



Grew new engagements from existing client base.


Participated on sales calls to prospective clients.


 

Tax Controversy

Prepared responses to multiple IDRs from IRS and Canadian Revenue Authority

 

Tax Audit Defense

Defended selection of transfer pricing comparable sets to IRS in written response.

 

KPMG LLP, Philadelphia, PA, 2003–2006

 

Manager-Transfer Pricing

Covered diverse set of industries, including, high technology, software, power systems, industrial equipment, advanced plastics, biotechnology and health care; 


prepared responses to IRS and foreign tax authority IDRs; 


prepared colleagues to testify before IRS; 


familiar with all the approved methods for establishing transfer prices among corporate affiliates;


reviewed transfer pricing for tax auditors and worked on FLSI documentation; presented a synopsis of the proposed services regulations to a client for CPE credits; analyzed client P&Ls and balance sheets; 


write and present proposals;  


mentored the career development of junior staff; solicited new clients.


 

Tax Defense Preparation 

Prepared materials and analysis on behalf of Director to defend client before IRS

 

Tax Controversy

Prepared responses to multiple IDRs from IRS and Canadian Revenue Authority

 

Tax Feasibility

Employed KPMG’s intangible holding company model, which calculates cost sharing and buy-in payments for profit splits from intangible assets for a tax feasibility project. Drafted transfer pricing planning studies designed to minimize client’s global tax rate.

 

Repatriated Income

Document appropriate transfer price U.S. parent should charge its foreign subsidiary for vanilla bean distribution services rendered.

 

Transfer Pricing Policy

Established transfer price between US parent and Canadian branch for industrial battery manufacturer.

 

PRICEWATERHOUSECOOPERS LLP, 1999–2003

 

Manager-Transfer Pricing – Washington DC, 12/00–5/02; Tel Aviv, Israel, 6/02–4/03.

Temporarily assigned to Tel Aviv office to manage all transfer pricing analysis projects in the office and participated in business development efforts:


Conducted assessments of existing client base and identified additional service offerings to generate revenue.


Lead team efforts to obtain new transfer pricing clients for the firm.


grew client base of newly formed Tel Aviv office; 


directed research, outreach, fiscal, and personnel management of Division;


collaborated on decisions impacting institute-wide management and activities;


established performance standards for practice with studies conforming to Section 482 IRS tax regulations or OECD Transfer Pricing Guidelines; 


prepared responses to IRS and foreign tax authority IDRs; covered diverse set of industries, including, finance, high technology, software, oil and gas and industrial equipment;


contributed to global profit alignment model, which calculated cost sharing and buy-in payments for profit splits from intangible assets; 


involved in proposal writing, model specification, estimation, and report writing; 


worked on intercompany agreements to implement transfer pricing policies.


 

Tax Controversy

Prepared responses to multiple IDRs from IRS and Canadian Revenue Authority

 

Financial/Banking Software   

Benchmarked appropriate transfer price for company that makes financial transaction software that facilitates inter-bank communication.

 

Merger and Acquisition

Valued intangible assets and determined best place to house assets, Israel or U.S. for merger between a telecom gateway company and telecom switching company to create voice over Internet protocol product. 

 

Transfer Pricing Analysis      

Evaluate value of and transfer prices for tangible and intangible assets for medical device company that manufactured high-tech tubes/vials that rapidly freeze and unfreeze bodily fluids.

 

    Manager-Tax Policy Analysis – Washington DC 10/99–12/00

Recruited junior level staff for National Economic Consulting (NEC) Team.   Spearheaded    development of NEC website. 

 

Minimum Wage

Evaluated impact of the U.S. minimum wage on manufacturing production levels in Puerto Rico.

 

Charitable Donations

Managed staff in estimating change in donation levels by charitable family foundations due to a change in the 2% de minimus rule.

 

Tax Exemption Status

Estimated size of the foreign sales corporation (FSC) tax exemption and impact of proposed phase out.

 

Health Care and Pharmaceuticals

Used regression model to estimate effects of global price controls on pharmaceutical research and development spending and on industry employment.

 

Nuclear Energy and Tariffs

Analyzed the market for nuclear steam generators and the impact of U.S. tariffs on generator replacement in the U.S.

 

 

CAPITAL ECONOMICS, Washington, D. C., 1997–1999

 

Economist

Prepared economic studies in anti-trust cases for expert witnesses to testify to in court; prepared price impact analysis to present before the U.S. DOJ and the U.S. FTC in defense of proposed mergers and acquisitions; specialized in statistical and econometric analyses involving M&As, JVs, and price setting behavior. 

 

Merger and Acquisition

Managed team of four analysts creating 5-year database of daily spot prices for 10 grain products in 8 cities to determine geographic boundaries of grain markets for 2 major grains and feed marketers. Constructed econometric model, calculating geographic boundaries for assorted grain markets.  Employed impulse response function, demonstrating equilibrium time path and price convergence. Minimized project costs by balancing use of senior and junior analysts.

 

Litigation – Lines of Inquiry and Deposition Preparation

Prepared lines of inquiry for lawyers to follow to depose witnesses.  Directed team of analysts in review and summary of 50 depositions to provide economic evidence opposing plaintiff’s motion for class certification. 

 

Litigation – Expert Report Writing

Drafted and edited sections of defense’s expert report opposing certification of independent service organizations, printer brokers, and printer end users as a distinct class for high speed printer manufacturer. 

 

Analyst Research

Supervised analyst research to determine interest rate volatility for mortgage backed securities from time series data. Instructed analyst in the use of econometric software and regression tools for mortgage and securities company.

 

Brand Divestiture

Performed econometric price projections to test unilateral effects of a proposed brand divestiture for a major distiller.

 

Antitrust Issues

Analyzed antitrust issues, including mortgage backed securities, aircraft and defense, telecommunication, high-speed printer, distilled spirits, heavy equipment, and oil and gas industries.

 

Other position held – ICF RESOURCES, INC., Research Assistant / Analyst, Fairfax, VA, 1988–1991. George Mason University, Fairfax, VA Lecturer on Environmental Economics (Fall Term 1996) and Information and Decision Management (Government 459). Public Policy Fellowship - Prepared policy briefs and drafted legislation.

 

 
EDUCATION

 

George Mason University, Fairfax, VA, Charles G. Koch Fellowship, 1996 (Completed all course work towards Ph.D.)

 

New York University, New York City, NY, MA, Economics 1994

 

University of Chicago, IL, BA in Economics 1988

 

Relevant Coursework – Price Theory, Macroeconomics, Statistics, Econometrics, Game Theory, Operations Research, Computational Modeling of Non-Linear Systems and Economic Regulation.

 

 

 
PUBLICATIONS

 

“Transfer Pricing: The New Temporary Cost-Sharing Regs.” The Tax Advisor, April 2009, p. 210

 

Contributing author to study on the effects of global price controls on pharmaceutical research and development spending and on industry employment, 2000. 

 

Contributing author to study on the market for nuclear steam generators and the impact of U.S. tariffs on generator replacement in the U.S., 1999.

 

Co-authored paper on market entry in the natural gas industry (unpublished).

 

Contributing author to report on the deferred presentment industry, looking at comparable interest charges in competing financing alternatives, 2000.

 

 
PRESENTATIONS

Presented intermediate transfer pricing seminar to Ryan clients in Canada (October 2014)

 

Participated in panel discussion on operational transfer pricing software solutions at the 2014 TP Minds Summit in Miami Florida (February 2014)

 

Presented introductory transfer pricing seminar to Ryan clients in Canada (July 2012)

 

Presented a review of the transfer pricing service regulations, which the IRS proposed in September 2003 to Subaru’s tax and accounting staff in December 2003.

 

Presented paper to the Center for Market Processes’ Weekly Seminar on Mojave Gas Company’s attempted entry into the California natural gas market (March 1995).

 



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