Scott F. Hesse Partner PwC

Transcription

1 Scott F. Hesse Partner Detroit, Michigan Office: (313) Cell: (248) Role/responsibility -- Scott Hesse is a Partner in 's International Tax Services Practice. Area or Industry of Specialization -- Scott has over 23 years of experience specializing in all phases of U.S. and international taxation. Experience -- In assisting clients minimize their global tax burden, Scott has worked with both "inbound" and "outbound" client companies to address transfer pricing issues, organizational restructuring options, Intangible Property structuring alternatives, repatriation planning strategies (including dividends, royalties, management fees, etc.), earnings and profits studies, subpart F income analyses and foreign tax credit utilization issues. Scott also has extensive experience in supporting the merger and acquisition activities of his clients, including completing buy-side tax due diligence reviews in connection with domestic and international transactions; identifying structuring options for both taxable and tax-free transactions; reviewing and implementing cross-border financing strategies; and providing structuring advice and implementation assistance for post-deal integration. Education/credentials/publications -- Scott is a graduate from the University of Michigan where he received his Bachelor of Business Administration degree. Scott is professionally affiliated with AICPA, MACPA, and International Fiscal Association.

2 Rohit Kumar Principal Washington, D.C. Office: (202) Role/responsibility -- Mr. Kumar is a principal and co-leader of s Tax Policy Services practice within the Washington National Tax Services practice. In his role, Mr. Kumar advises clients on all aspects of domestic policy including tax policy. Area or Industry of Specialization His insights and knowledge enable companies to assess critical policy issues more effectively and develop legislative strategies to address those issues from both a technical and political perspective. Experience -- Prior to joining, Mr. Kumar served as the Domestic Policy Director and Deputy Chief of Staff in the Office of Senate Republican Leader Mitch McConnell. He served 11 consecutive years in the Office of the Republican Leader, having previously been Director of Policy and Senior Counsel to Senate Majority Leader, Bill Frist and Senior Policy Advisor and General Counsel for Senate GOP Leader, Trent Lott. In all of these roles, Mr. Kumar worked in close collaboration with Senate leaders in developing and implementing all aspects of domestic policy including tax, trade, budget, and health care. Mr. Kumar also held positions in the Office of Senator Phil Gramm as Legislative Director and Chief Counsel, the Senate Committee on Banking, Housing and Urban Affairs as Deputy Chief Republican Counsel and clerked in the United States Court of Appeals for the Fourth Circuit. Mr. Kumar has been named in Roll Call as one of the fifty most influential staffers for mastery of policy and procedure and access to decision makers at key times. He was described in the Washington Post publication Who Runs Gov as, an expert in both politics and policy and also listed in the Almanac of the Unelected as an expert in tax, trade, banking/financial services and immigration. Education/credentials/publications -- Mr. Kumar received his J.D. from the University of Virginia. He graduated magna cum laude with a B.A. from Duke University.

3 Michael Danilack Principal Washington, D.C. Office: (202) Cell: (678) Role/responsibility -- Mike Danilack is a Principal in s Washington National Tax Services practice and plays a key role in 's Global Tax Controversy and Dispute Resolution network. Area or Industry of Specialization -- Mike s work focuses on international tax dispute resolution through the mutual agreement procedures and APAs, on IRS controversies involving international tax and transfer pricing issues, and on general cross-border tax planning. Experience -- Before joining in December 2014, Mike served as the Deputy Commissioner (International) in the IRS Large Business and International Division where he was responsible for all international tax matters for the IRS, including serving as the U.S. Competent Authority. As Competent Authority, Mike represented the United States on all cross-border matters pertaining to dispute resolution, treaty interpretation, and information exchange. While Deputy Commissioner, Mike completely redesigned the IRS s international tax programs, creating the Advance Pricing and Mutual Agreement program, the Transfer Pricing Practice, the International Business Compliance function (responsible for examination of international corporate issues), and the Foreign Payments Practice (responsible for administration and enforcement of all withholding tax and FATCA issues). He also designed and implemented the comprehensive knowledge management tools that now serve as the basis for the IRS s international enforcement strategies. Mike headed the IRS effort to implement FATCA, which led to a new multilateral process for the automatic exchange of data among treaty partners. In addition, Mike designed and initiated the Forum on Tax Administration s MAP Forum, which now works to reform the mutual agreement procedures and enhance competent authorities dispute resolution capabilities. Education/credentials/publications -- Mike earned a B.A. from University of Pennsylvania and a J.D. and LL.M. from New York University School of Law.

4 Matthew Ryan Partner New York, NY Office: (646) Role/responsibility -- Matthew Ryan is a UK tax partner based in our New York office where he leads the UK tax desk. Area or Industry of Specialization -- Matt has worked on international groups for his entire career, and has specialized solely on international tax issues for the past 15 years, advising a range of quoted and private multinational companies of all sizes in all sectors but predominantly US MNC's. Experience -- Matt has a key role in the UK firm s international structuring practice. Prior to moving to New York Matt led the UK s Inbound Structuring Group and was responsible for developing the firms strategy for maximising the benefits of the UK s corporate tax reforms for inward investors to the UK which has involved liaising closely with the UK Revenue and Treasury authorities. Additionally, Matt was a member of s International Tax Structuring Planning Group, a core team of partners drawn from the global network with the responsibility for assisting jurisdictions develop best in class inbound and outbound investment structures. As a result of these roles Matt has knowledge of the key aspects of many of the tax systems around the world and has an excellent personal network of the leading International Structuring partners in the Global organisation. Education/credentials/publications -- Matt holds an Economics and Business Finance Degree (BsC) and is a qualified accountant with the Institute of Chartered Accountants in England and Wales. He is also the author of a number of articles on International Tax.

5 Kevin Daly Director Detroit, MI Office: (313) Cell: (248) Role/responsibility -- Kevin Daly is a Director with 's Transfer Pricing practice. Area or Industry of Specialization -- Kevin is primarily focused on serving multinationals in the life sciences, automotive, and chemical industries. Experience -- Kevin has assisted clients in obtaining bilateral APAs, fast-track dispute resolution, domestic and international restructurings, international business expansion and supply chain planning, IP management and migration strategies, and M&A due diligence, in additional to numerous global documentation engagements. Education/credentials/publications -- Kevin holds a bachelor s degree in economics and management from Albion College, and a JD from the University of Toledo College of Law.

6 John Ranke Partner Chicago, IL Office: (312) Cell: (248) Role/responsibility John is the US and Americas Value Chain Transformation Leader and an international tax partner based in Chicago. Area or Industry of Specialization -- John specializes in leading large-scale strategic tax optimization engagements for multinational companies that are designed to deliver long-term tax efficiency through the implementation of business alignment, foreign tax reduction, and cash redeployment structures. Experience -- Throughout his 27 years with the firm, John has held a variety of positions within the US International Tax Services (ITS) practice, including National Practice Leader, leader of the ITS Business Solutions practice, and leader and cofounder of the Vision practice dedicated to delivering effective tax rate reduction to complex multinational companies. Education/credentials/publications -- John is a CPA and an attorney in the state of Michigan and a member of the AICPA, MACPA, American Bar Association, State Bar of Michigan, and International Fiscal Association.

7 Jeffrey D. Brown Partner Detroit, Michigan Office: (313) Cell: (313) Role/responsibility -- Jeffrey Brown is a Partner in 's International Tax Services Practice. Area or Industry of Specialization -- Jeff has more than 20 years of experience in restructuring U.S, based multinational corporations to optimize their global tax burden. Jeff is also part of 's national integrated global structuring ("IGS") practice. His areas of his focus include -- International mergers & acquisitions; Tax-aligned supply chain planning; International tax accounting; Foreign tax credit planning; Cross border financing structures; and Repatriation strategies. Experience -- Jeff has worked extensively with automotive OEMs and their suppliers. He is a certified enterprise lean / six sigma yellow belt. In addition to the automotive industry, Jeff has served clients in other manufacturing industries including medical device manufacturers and the chemical industry. His experience includes working with non-manufacturing companies in the financial services, private equity, and retail sectors. Prior to joining in January of 2011, Jeff spent fifteen and a half years with Deloitte. He also spent three years as an adjunct instructor at Walsh College where he co-taught a graduate degree course in international tax. Education/credentials/publications -- Jeff received both his Bachelor and Master degrees in accounting from Brigham Young University. Jeff is a member of the AICPA and MACPA.

8 Gerard Cops Partner Luxembourg Office: Cell: gerard.cops@lu.pwc.com Role/responsibility -- Gerard is a Partner - International Tax Services at PricewaterhouseCoopers in Luxembourg. Area or Industry of Specialization -- He has 20 years of experience in international tax planning and value chain transformation. Gerard leads Luxembourg s Value Chain Transformation practice. Experience -- Gerard s primary area of expertise is integrated global structuring, covering business model transformation, corporate simplification, holding and financing structuring, and intellectual property planning. He advises and assists large multinational corporations on the feasibility, design, implementation and operation of their EMEA business, finance, tax and legal model, in an integrated manner. In these projects, he closely interacts with the Advisory, Finance, Tax & Legal teams. Education/credentials/publications -- Gerard holds a Master Degree in Business Engineering from the University of Louvain and a Master Degree in Tax Management from the Solvay Business School in Brussels (cum laude).

9 Elizabeth Masek Director Detroit, MI Office: (313) Cell: (248) Role/responsibility -- Beth is a director in s International Tax Services. Area or Industry of Specialization -- With over 25 years of corporate and international tax experience, Beth specializes specializing in U.S. international taxation primarily for U.S. based manufacturing and financial services companies. Experience -- Prior to joining as a Director in 2009, Beth held positions with Ford Motor Company, Ford Motor Credit Company and General Electric Capital Corporation. Beth has extensive experience working with large multinational clients to address Subpart F income planning, including application of the active financing exception to Subpart F income, acquisition planning including post acquisition integration, Intellectual property and value chain planning, foreign tax credit planning, cross border financing structures, foreign currency transactions including foreign currency hedging, internal restructuring transactions and cash repatriation strategies. Education/credentials/publications -- Beth received her undergraduate degree from Boston College, her law degree from the Catholic University of America and her LLM from Georgetown University. Beth is a member of the Michigan Bar Association.

10 David S. Chen Partner Detroit, Michigan Office: (313) Cell: (248) Role/responsibility -- David Chen is a Partner in 's Quantitative Solutions Practice. Area or Industry of Specialization -- David has 20 years of experience in corporate and international tax planning and quantitative solutions. Experience -- David currently leads the International Tax Quantitative Solutions practice for the Greater Michigan and Lake Erie Markets. The Quantitative Solutions practice works with multinational companies to assess the current state of their international tax attributes and drive the quantitative analysis of future planning and structuring opportunities. To this end, David brings his 20 years of experience in corporate and international tax planning and quantitative analysis. He has worked on a variety of international tax planning projects for U.S. based multinational companies, including foreign tax credit studies, foreign source income planning, earnings and profits and tax pool analyses, repatriation planning projects, expense apportionment and HQ charge-out projects, international tax reform modelling projects and international tax reporting projects. David worked closely with inbound clients on U.S. tax planning and efficient repatriation of cash from the U.S. David also leverages his international quantitative experience into other areas such as domestic production activities deduction. Education/credentials/publications -- David received his undergraduate degree from the University of Michigan and his law degree from the University of Detroit. David is a certified public accountant and is a member of the AICPA and the Michigan Bar Association.

11 Chip Harter Principal Washington D.C. Office: (202) Cell: (240) Role/responsibility -- Chip Harter is principal in the PricewaterhouseCoopers LLP Washington National Tax Practice. Area or Industry of Specialization -- His practice focuses on advising multinational corporations and financial institutions on international tax planning and on tax issues arising with respect to financing transactions and financial instruments. Experience -- As a senior technical review partner within 's national tax office, Chip participates in the review of the tax provisions of many financial institutions and multinational corporations. He joined PricewaterhouseCoopers in 1999 after having practiced tax law with Baker & McKenzie for 18 years. From 1989 through 1994, he was an Adjunct Professor of Taxation in the Graduate Tax Program of IIT Chicago-Kent College of Law. Education/credentials/publications -- Chip earned a JD from the University of Chicago Law School in 1980, where he was Comments and Articles Editor of the University of Chicago Law Review, and he graduated magna cum laude from Harvard College in Chip is a past Chair of the Financial Transactions Committee of the American Bar Association Section of Taxation. His recent publications include: "The Devil is in the Details: Problems, Solutions and Policy Recommendations with Respect to Currency Translation, Transactions and Hedging," Vol. 89, No. 3 Taxes, p. 199 (March 2011) (with John D. McDonald, Ira G. Kawaller, and Jeffry P. Maydew); "Inherently Hedgeable: Hedging Foreign Currency Exposures Arising From Branch Operations of a CFC," Vol. 37, No. 5 International Tax Journal, p. 11 (Sept. - Oct. 2011) (with Rebecca Lee and David Shapiro); and "Hedges of Foreign Currency Risk Associated with Debt Instruments Held as Capital Assets," Vol. 36, No. 6 International Tax Journal, p. 5 (Nov. - Dec. 2010) (with Michael J. Harper).

12 Brian Chrzanowski Manager Detroit, MI Office: (313) Cell: (248) Role/responsibility -- Brian is a Manager in 's Greater Michigan market and a member of the International Tax Services practice. Area or Industry of Specialization -- He specializes in international taxation and has worked with clients on a broad range of tax issues including accounting for income taxes (ASC 740), global mergers and acquisitions, organizational restructuring, repatriation planning, cross-border financing, and international tax compliance. Experience -- Prior to joining the International Tax Services practice, Brian served as a member of the Business Process Management team in 's national Tax Process Office and as a federal tax practitioner in 's Greater Michigan market. Brian has served an array of clients in the automotive industry as well as clients in the industrial manufacturing, consumer products, and software application industries. Education/credentials/publications -- Brian graduated (with honors) from the University of Michigan where he received Bachelor of Business Administration and Master of Accounting degrees. He is a Certified Public Accountant and is a member of the AICPA, MACPA and the International Fiscal Association.

13 Bill Hahn Principal Detroit, MI Office: (313) Cell: (248) Role/responsibility -- Bill Hahn is Transfer Pricing Principal located in Detroit, serving automotive, industrial, consumer products, and medical products companies. Area or Industry of Specialization -- He is the global leader of the Automotive Transfer Pricing Network for PricewaterhouseCoopers and has over 25 years of transfer pricing and valuation experience focused on assisting clients with managing the arm's length standard around the world and the organizational structures around intercompany transfer prices. Experience -- In addition to documentation, policy formulation, APA and examination resolution projects for clients, Bill also established and managed a transfer pricing practice in Mexico City, Mexico, where he resided for three years. Bill has been recognized as one of the World's Leading Transfer Pricing Advisors in 2011 by Euromoney and is a frequent author and speaker. Education/credentials/publications -- Bill holds a B.A. in Economics from Northern Illinois University and an M.B.A. from the University of Illinois.

14 Russell Loose Director Detroit, MI Office: (313) Cell: (586) Role/responsibility -- Russell is a Director in 's Greater Michigan market and a member of the International Tax Services practice. Area or Industry of Specialization Russell has over 10 years of experience specializing in mergers & acquisitions and international taxation Experience -- Russell began his career as a tax compliance specialist and subsequently shifted focus to M&A and lastly upon ITS. He has assisted clients with cross boarder complex structuring and restructuring transactions, maximizing attribute utilization following acquisitions, stock and asset basis calculations, tax purchase accounting analysis, foreign tax credit modeling, and coordinating and executing tax due diligence for clients primarily in the automotive and manufacturing industries. He has been involved in numerous multinational mergers and acquisitions ranging in size from $10 million to over $5 billion. Russell has participated in tax transaction service engagements including Ford Motor Company, Kellogg Corporation, Lear Corporation, Masco Corporation, Metaldyne Corporation, Whirlpool, Perrigo Corporation, ZF AG, and MD Investors Corporation. Education/credentials/publications -- Russell graduated from Central Michigan University where he received Bachelor of Business Administration degree. He is a Certified Public Accountant and is a member of the AICPA.

15 Jarrod A. Wood Director Washington D.C. Office: (202) Cell: (517) Role/responsibility -- Jarrod Wood is an International Tax Services Director in PricewaterhouseCoopers Washington National Tax Practice. Area or Industry of Specialization -- Jarrod has over 9 years of experience specializing in U.S. and international taxation. Experience -- Jarrod joined in 2006 as part of the International Tax Services Group in Detroit, MI. His experience includes both inbound and outbound tax planning, cross border legal entity restructuring, cross border financing & large scale repatriation projects, tax efficient supply chain planning, foreign income tax reporting for US multinationals, and quantitative modelling focused on ETR and cash tax management. In addition to his international tax experience, Jarrod has significant experience working on ASC 740 (accounting for income taxes) related projects (both audit support and consulting for nonaudit clients), UTP reviews and assessments, and federal tax compliance. Jarrod has worked on a variety of clients spanning several industries including automotive, retail & consumer goods, utilities, software & ecommerce, and banking & capital markets. Education/credentials/publications -- Jarrod holds both a BBA in Accounting & Finance and a Master of Accounting degree from the University of Michigan. He is a Certified Public Accountant, licensed in the State of Michigan and the District of Columbia.