Manager Service

Javier G. Salinas

**** ***** ****** ***., ** #*20 . Washington, DC 20005 . 202-***-**** .

******.*.*******@*****.***

EXPERIENCE

Ernst & Young, LLP, National Tax Department, Washington, DC

September 2007 to Present

Manager. As part of the International Tax Services group, advise

multinational corporations and draft tax opinions, IRS Chief Counsel ruling

requests, and technical memoranda on various aspects of international tax

planning, including outbound transfers of property under section 367, stock

migration transactions under section 7874, international reorganizations,

anti-deferral provisions under Subpart F, application of tax treaty

provisions and limitations on benefits, inbound tax and withholding issues

under section 1442, and foreign tax credits; prepare firm educational

materials on technical subjects; and draft technical summaries of Treasury-

issued guidance for firm practice offices and clients.

Office of Associate Chief Counsel (International), Internal Revenue

Service, Washington, DC July 2003 to

August 2007

Attorney-Advisor. Interpreted tax treaties and tax information exchange

agreements (TIEAs); participated in TIEA negotiations; assisted in the tax

information exchange process, including acting as lead counsel for

negotiations with the Costa Rican Ministry of Finance; drafted memoranda on

various inbound and outbound international tax issues arising under the

Internal Revenue Code such as on source, residency, and withholding;

drafted taxpayer guidance on U.S. competent authority procedures; conducted

legal research on various domestic and foreign tax law issues, statutes,

and administrative guidance; advised the U.S. competent authority on

international tax and cross-border litigation matters.

United States Department of the Treasury, Washington, DC

June 2006 to April 2007

Senior Advisor to the General Counsel (on detail). Reviewed, briefed, and

advised on U.S. tax guidance, including regulations concerning source of

income, corporate reorganizations, carryover of tax attributes, transfer

pricing for services, allocation of foreign tax expenditures, previously

taxed earnings and profits, currency gain/loss for qualified business

units, treatment of subsidiary stock within consolidated groups, and

reporting requirements; advised on new U.S. income tax treaties with

Belgium and Bulgaria; reviewed for General Counsel clearance proposed

testimony before Congress and correspondence of the IRS and the Office of

Tax Policy on matters such as money service businesses and Bank Secrecy Act

compliance, IRS tax shelter initiatives, tax patents, executive

compensation and backdating of stock options, corporate compliance, and

reduction of the tax gap; advised on tax and other matters in providing

legal support to the Secretary and Deputy Secretary.

The Honorable Juan F. Vasquez, United States Tax Court, Washington, DC

April to July 2003

Attorney-Advisor. Conducted legal research, analyzed briefs, and drafted

opinions on various issues; participated in conference calls with the

parties; reviewed judicial memoranda on issues contested among the judges

and discussed issues with judge in preparation for court conference

deliberations; served as legal intern from May to July 1998.

The Honorable Filemon B. Vela, United States District Court, Brownsville,

Texas July to September

2002

Law Clerk. Conducted legal research; briefed judge on cases and legal

issues; drafted opinions, memoranda, and orders; attended trial proceedings

and pretrial conferences.

CLERKSHIPS/INTERNSHIPS

The Honorable Lynn N. Hughes, United States District Court, Houston, Texas

Fall 1998

ICC International Court of Arbitration, Paris, France

July to August 1998

Martin & Maynadier, Paris, France

July 1997

Von Wobeser y Sierra, S.C., Mexico City, Mexico

May to July 1997, Summer 1996

EDUCATION

Boston University, Boston, Massachusetts

May 2002

Master of Laws in Taxation

University of Houston, Houston, Texas

August 1999

Juris Doctor and Master of Business Administration, Concentration in

Finance

The University of Texas, Austin, Texas

December 1994

Bachelor of Arts in Spanish

HONORS/ACTIVITIES

Government of Spain - Young Hispanic Leaders Program, Santander and Madrid,

Spain, June 2006

Judge James DeAnda Scholarship Award Recipient, May 1997

Tulane Institute of European Legal Studies, Universit Panth on-Assas,

Paris, France, July 1997

University of Houston Mexican Legal Studies Program, Universidad Nacional

Aut noma de M xico, Mexico City, Mexico, June 1996

Hispanic Law Students Association, President 1996-97, Member 1995 to 1999

LECTURES/PUBLISHED WORK

American University Washington College of Law, Washington, DC

March and October 2005

Guest Lecturer. U.S. Tax Considerations of Doing Business in Latin America.

The OECD Tax Competition Initiative: A Critique of its Merits in the Global

Marketplace, 25 HOUS. J. INT'L L. 531 (2003).

LANGUAGES/MEMBERSHIPS/INTERESTS

Fluent in Spanish, Highly Proficient in French

Member of the State Bar of Texas (1999), District of Columbia Bar (2000),

State Bar of California (2005); District of Columbia Bar, Member, Board of

Governors (2008-Present), Secretary (2008-2009); Hispanic Bar Association

of the District of Columbia, Treasurer (2007-2011)

Interests include wine collecting, traveling, and gourmet cooking

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