International Operations

Sara Verkest

**** ****** ******, ***. *** ? Hoboken, NJ 07030 ? Mobile: 917-***-**** ?

E-Mail: ********@*****.***

EXPERIENCE:

Gide Loyrette Nouel, LLP - New York, New York

Tax Associate, January 2008 - current

. Advising clients on various aspects of international and U.S. federal

income taxation, including income tax treaty and withholding tax

analysis.

. Drafting memoranda regarding key international tax issues, including

entity classification, U.S. trade or business, ECI, Subpart F, sourcing

of income, PFIC, FIRPTA, and the new FATCA regime.

. Advising issuers and underwriters on tax aspects of multi-jurisdictional

144A equity and debt offerings.

. Advising foreign and U.S. commercial paper issuers on tax aspects related

to multi-jurisdictional receivables financing programs.

. Advising numerous U.S. companies on tax structuring of foreign

operations, foreign acquisitions, and foreign debt and equity issuance.

. Advising numerous non-U.S. companies on tax structuring of U.S.

operations, acquisitions, and debt and equity issuance.

. Structuring the establishment of a major asset management group with

operations in the U.S. and Europe.

PricewaterhouseCoopers, LLP - New York, New York

International Tax Senior Associate, September 2005 - January 2008

. Substantial experience with cross-border transactions. Research and

analysis of complex U.S. cross-border issues, including debt push-down,

check-the-box/holding company planning, Sections 367 and 368 issues in

corporate reorganizations, interest and dividend withholding under

various U.S. income tax treaties and anti-conduit regulations.

. Devised strategies to address intricate foreign cross-border issues,

including implementation of financing structures and foreign withholding

tax minimization through the establishment of foreign holding company

structures.

. Dealt with European, Latin American and Australian offices and lawfirms

in order to achieve an optimal tax structure with respect to

international operations, assisting on the coordination of U.S. and

international tax projects.

. Advised diverse client portfolio, including leading U.S. multinational

manufacturing and service companies.

. Received the highest employee performance rating.

EDUCATION:

University of Florida, Levin College of Law - Gainesville, Florida

LL.M., International Tax Specialization, May 2005

Universit Libre de Bruxelles - Brussels, Belgium

Graduate specialization in tax law, cum laude, July 2004

Katholieke Universiteit Leuven - Leuven, Belgium

Master in Laws, cum laude, June 2003

BAR ADMISSION AND MEMBERSHIPS:

. Admitted to the New York Bar

. Member of the American Bar Association (International Tax Committee) and

the New York State Bar Association

LANGUAGES:

. Fluent in Dutch and French

. Basic knowledge of German and Norwegian

IMMIGRATION STATUS:

. Authorized to permanently work in the United States (green card holder)

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