International Manager

JO-RENEE HUNTER

248-***-****(c)

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

SUMMARY

** ***** ** ********** ** the international tax arena with concentration on

both income and operational taxes in the U.S. and abroad. I have had

worldwide responsibility for structuring everyday operational transactions,

mergers, acquisitions, and dispositions in the most tax efficient manner.

My areas of expertise include transfer pricing, cross border transactions,

effective tax rate and cash flow planning, US and foreign tax audits,

establishing SOX procedures and compliance, FIN 48 requirements and tax

compliance. I have been a speaker at numerous seminars on US International

Taxation and am a Board of Advisor for the Journal of International

Taxation.

PROFESSIONAL EXPERIENCE

LEGAL

MWV (Formerly MEADWESTVACO) - Richmond, VA

2/07 -6/10

Senior Director International Tax Counsel

. Managed the international tax group to maximize foreign tax

benefits and minimize global tax costs.

. Advised U.S. and foreign senior management on international tax

issues including issues related to mergers, acquisitions, joint

ventures, dispositions, wholly owned start-ups.

. Managed a full range of International Tax Services including tax

return preparation (US and 150 non-US returns) and review, tax

research, and preparation of technical memorandums.

. Managed and developed transfer pricing policies through

relationships with outside advisors and ensured compliance with US

and non-US transfer pricing documentation laws.

. Developed international tax polices and provided input into

financial policy matters.

. Managed, coordinated and reviewed compliance processes and results

with tax staff and outside accounting firms and auditors to assure

accurate and timely reporting of financial and tax data in

compliance with Sarbanes-Oxley and US GAAP principles: ACS 740,

FAS 109, FIN 48 and APB 23.

. Provided expertise and guidance to tax and accounting personnel in

reporting foreign income and taxes in the enterprise's worldwide

financial statements, including the review of all international

aspects of non-US income taxes quarterly and annually, as well as

making recommendations regarding the provision of foreign tax

contingencies.

. Worked closely with Treasury to manage worldwide cash flows

efficiently; coordinated accounting and planning for dividends,

loans and FX issues.

. Managed international portion of federal tax audits and provide

guidance and direction to local advisors regarding foreign tax

audits, including development of audit strategies and negotiation

of tax dispute settlements.

. Supervised, developed and mentored professional tax staff through

the delegation of challenging assignments, coaching, training and

by establishing the highest levels of expectations for each staff

member.

. Effectively lead efforts for change.

Accomplishments

. Developed, supervised and marshaled arguments and strategies to

increase chances of successfully defeating Brazilian and Canadian

tax authorities attacks against the 2002 tax year treatment for a

debt/equity hybrid instrument: $US$117M tax liability.

. Successfully negotiated and settled with IRS Appeals the tax

treatment for a Japanese Capital Loss deduction: US$32M tax

savings.

. Developed and managed the restructure of a US$500M business unit's

non-US operations capture the opportunity to divest the business

unit's foreign subsidiaries in a series of tax free transactions:

US$35M in tax savings.

. Managed, developed and negotiated the elimination of approximately

50% of MWV's 150 foreign legal entities through liquidations and or

mergers of legal entities. Annual G&A cash savings of

approximately US$1.5M.

. Developed and managed the adoption of Toll manufacturing by a US

business unit localizing its production of product in China for

export outside of China. 17% Chinese import and export duties

eliminated.

. Developed, trained and mentored subordinate staff members to

identify and solve tax issues.

NISSAN NORTH AMERICA, INC. - Gardena, CA

8/04 - 10/06

Senior Tax Counsel

. Developed & implemented global (worldwide) tax planning strategies

that minimized Nissan's and Renault's (Nissan's wholly owned

parent) global effective tax rate for financial reporting purposes.

. Advised U.S. and foreign senior management on Global, US

International (inbound and outbound), US Federal, and State and

Local tax issues.

. Minimized taxes resulting from domestic, state and local and

international operations and transactions.

. Performed international research, planning and analyses regarding

Foreign and U.S. international tax audit issues.

. Performed tax research to support & defend Federal, State and Local

and International tax-filing positions.

. Provided transfer-pricing strategy for international markets, &

counsel for transfer pricing matters.

. Provided counsel on the structuring of international business

transactions both with affiliates & third parties to ensure global

tax optimization.

Accomplishments

. Winner of Nissan's 2006 V-up Global Accomplishments Award -

Infiniti Global Taxation & Collection Process

. Developed and provided counseling for the structure of a product's

global launch with affiliates & third parties to ensure global tax

optimization: projected aggregate tax savings $195-300 million.

. Proposed changes in tax accounting methods to accelerate annually

an additional $300 million of tax deductions.

. Revised a tax planning idea to increase tax deductions annually by

$113 million.

. Successfully negotiated tax settlements with States generating

significant tax savings.

GENERAL MOTORS CORPORATION, INC. - Detroit, MI

5/93 - 8/04

Senior Tax Counsel

Senior Tax Attorney (1993-1998)

1. Senior International Tax Counsel advising U.S. and foreign senior

management on international tax issues related to mergers,

acquisitions, joint ventures, dispositions, and wholly owned start-

ups for GM and Delphi Automotive in Asia Pacific.

2. GM's Senior Tax Counsel for GM and its Delphi division's largest

Asia Pacific operations: Japan, Korea, India and Australia.

. Eliminated and minimized taxes resulting from international

operations and transactions.

. Emphasis on tax laws of Australia, Japan, Korea, the United States,

Singapore and other Asia Pacific countries.

. Performed international research, planning and analyses regarding

Foreign and U.S. international tax audit issues.

. Senior International Tax Counsel for GMAC and its related financial

products affiliates.

. GM's Senior International Tax Counsel for e-GM, GM's Internet

businesses.

. Senior Domestic Tax Counsel for GM's dealerships and related

restructures, alternative fuel joint ventures, and real estate

partnerships.

. Senior State and Local Tax Counsel for select States.

. IRS Appeals Coordinator and Senior Tax Counsel for GM's 1991-1994

IRS Appeals Case.

Accomplishments

. Lead Tax Counsel for the acquisition of a US $5 billion Korean

automotive company with international operations in over 38 different

countries. Developed, supervised and marshaled arguments and

strategies that would have created tax savings of US$500 to 700

million.

. Established the legal and operating structures, and trade flows for

GM's first wholly Japanese automotive vehicle and parts and

accessories import and distribution company. Projected annual

sales over US$750,000 million.

. Lead Tax Counsel for GMAC Commercial Mortgage Group's acquisition

of several billion (US) dollars of Japanese non performing loans

using Japanese TK structures.

. Developed, supervised and marshaled arguments and strategies that

successfully supported a US$202 million Australian capital gains

tax issue. Closure of this issue, also, cleared the way for the

elimination of US$260 million in Australian dividend withholding

taxes and the preservation of a US$ 207 million Australian tax

deduction.

. Successfully coordinated and actively participated in the

negotiations for GM's 1991-1994 Appeals case ( includes EDS and

Hughes Electronic Corporation Appeals Issues) using the IRS'

recently developed MAPI procedures, designed to reduce the time it

takes taxpayer's Appeals cases to be resolved. MAPI reduced GM's

1991-1994 Appeals Case cycle from 4-5 years to 12-18 months.

. Developed, supervised and marshaled arguments and strategies to

receive private letter rulings, from the Internal Revenue Service

and Australian Tax Office, that cleared the way for a corporate "D"

reorganization of GM's Australian automotive operations, over

US$500 million in tax savings generated.

. Developed, negotiated and successfully argued the deductibility of

a $US$285 million currency loss that was triggered when a foreign

DASTM branch was incorporated. The position caused the IRS to

issue a FSA to discourage other taxpayers from using the argument,

and encouraged the redrafting of the currency regulations to remove

this ambiguity.

3. Developed, supervised and marshaled arguments and strategies to

successfully treat a US$47 million cash remittance as a stock

redemption when there was no change in the number of shares held by

the US shareholder.

4. Successfully negotiated tax settlements with several States

generating tax savings in excess of $25 million.

ARVIN INDUSTRIES, INC. - Columbus, IN 6/90 - 5/93

International Tax Counsel/Manager

5. Responsible globally for minimizing taxes resulting from

international operations and transactions. Emphasis on tax laws of

The Netherlands, England, France, Spain, Germany, Italy, Canada,

Mexico, Australia, Brazil, South Africa, and the United States.

6. Advised U.S. and foreign senior management on acquisitions,

dispositions, operations and transactional tax issues.

7. Performed international research, planning and analyses regarding

Foreign and U.S. international tax issues.

8. Identified and recommended structures for international cross

border, intercompany financing, foreign exchange and hedging

treasury transactions. Assisted the Legal Department with the

design of corporate structures and other special projects.

9. Reviewed tax provisions and financial statements to ensure that they

reflected planning ideas that maximize earnings per share.

10. Performed U.S. international tax compliance and assisted with IRS

audits.

11. Ensured that tax compliance in foreign jurisdictions was done and

that proper procedures to substantiate foreign tax returns upon

audit by foreign officials were established. Assisted with foreign

audits. Assisted with the establishment of tax oriented accounting

systems and procedures to capture data necessary to perform US

international tax compliance.

12. Performed various tax administration functions.

McDERMOTT, WILL & EMERY, Chicago, IL 6/88 - 6/90

Associate, Corporate Tax Department

13. Performed domestic and international research and planning for

corporations, partnerships, trusts and exempt entities.

14. Prepared client letters and internal memoranda to summarize research

findings. Co-authored Illinois Institute for Continuing Legal

Education's chapter on the Tax treatment of Corporate Readjustments.

PRE-LEGAL

BEATRICE COMPANIES, INC., Chicago, IL 6/84 - 1/88

Acting Manager/Senior International Tax Analysis International

Examinations

15. Coordinated Beatrice's International IRS audit for taxable years

1982, 1983 and 1984. Prepared responses to Information Document

Requests. Determined which Notice of Proposed Adjustments should be

agreed/disagreed with, assisted in the preparation of 30-day

letters, and Appeals protests and a Tax Court Petition.

16. Extensive interaction with Internal Revenue Field and Appellate

Agents and outside legal counsel.

Senior International Tax Analyst International

Compliance/Research and Planning

17. Performed international compliance for controlled foreign

corporations, and extensive international research, planning and

analyses on TRA 86's effect on Beatrice's foreign operations.

Tax Analyst - Domestic Research and Planning

18. Performed research, planning and compliance for corporate

reorganization, liquidation, 338, contribution and distribution

transactions.

19. Tracked current TRA 84 Treasury and Congressional Legislation and

prepared a proposed law and its effect analyses.

MONTGOMERY WARD & COMPANY, INC., Chicago, IL 7/82 -

6/84

Tax Analyst III

20. Performed tax compliance, reserve analyses, research and developed

data processing systems to access information, prepared schedules,

returns and developed methods to analyze data.

KEEBLER COMPANY, Elmhurst, IL 9/80 - 7/82

Internal Auditor

PEAT, MARWICK, MITCHELL & COMPANY, Los Angeles, CA 7/79 -

8/80

Tax Specialist/Auditor

EDUCATION

Illinois Institute of Technology Chicago Kent College of Law - LEGAL -

Chicago, IL 1984-88

JURIS DOCTORATE

Honors - American Juris Prudence Award

De Paul University - GRADUATE - Chicago, IL 1981-83

M.S. in Taxation, plus Concentration in International Business

University of Illinois - UNDERGRADUATE - Urbana, IL

1975-79

B.S. in Accountancy

INTERNATIONAL EDUCATION

International Tax Academy - Amsterdam, Holland

Principals of International Taxes, European Corporate Taxes

International Tax Aspects of Banking, Financial and Treasury Transactions

International Tax Aspects of Investments, Acquisitions and Mergers

PROFESSIONAL LICENSES

Licensed to Practice Law in Illinois, Michigan and Washington D.C.

Certified Public Accountant for Illinois and California

PROFESSIONAL ORGANIZATIONS AND MEMBERSHIPS

Journal of International Taxation, Board of Advisor

International Fiscal Association, Member

American Bar Association, Section of Taxation

Former Chair, Foreign Activities of US Taxpayers Committee

Former Chair, Women and Minorities Committee

Championed the ABA, Section of Taxation's Presidential Showcase -

"Diversity a Vision for Lawyers in the 90's"

Nomination Committee and Committee on Committees, Member

Government Submission Committee, Member

Counsel on State Taxation, Member

SEMINAR MODERATOR AND PRESENTER, International and domestic tax issues

for mergers, acquisitions, joint ventures,

dispositions, and wholly owned start-ups, for:

Tax Executive Institute American Conference

Institute

International Fiscal American Bar Association

Association

Practicing Law Institute Tax Officer's Summit

American Institute of CPA's

NAACP, Former Executive Board Member for Chicago's Southside Branch

Project Might, Highland Park High School and Adult Education Program,

Advisory Board/P.A.C.T

Indianapolis Department of Transportation, BOARD OF DIRECTORS, Former

Director, Indianapolis, Indiana

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