Life Insurance Sales

EDUCATION

New England School of Law, Boston, Massachusetts

Juris Doctorate, Magna Cum Laude, May 1998

G.P.A.: 3.60 Class Rank: 5/189

Honors: New England Law Review, Case & Note Editor

New England Scholar (1995-98)

Dean's List (1995-98)

ASCAP Nathan Burkan Memorial Competition 1997

Who's Who: American Law Students (1995-98)

State University of New York at Plattsburgh, Plattsburgh, NY

Bachelor of Science in Computer Science, May 1990

EXPERIENCE

Marriott International, Inc., Bethesda, MD

Vice President & Global Tax Counsel, March 2010 to Present

Senior Director - International Tax Counsel, October 2007 to March 2010

Advise on all aspects of global tax planning, policy, and compliance.

Design and implement strategic Federal, state, foreign, and cross-border

tax savings initiatives, including, but not limited to, mergers &

acquisitions, reorganizations and restructurings, Subpart F, foreign tax

credits, IP planning, and tax efficient financing alternatives. Oversee

Marriott's global transfer pricing policy and compliance obligations.

Assist with managing all relevant Federal and international examinations,

appeals activity, and related controversy matters. Draft and review

Marriott's contracts for tax related issues associated with licensing,

partnering, and customer agreements in order to maximize Marriott's tax

position. Play a key role in managing Marriott's US and worldwide

effective tax rates. Inform senior management on all past, present, and

potential future tax legislation and trends that could affect Marriott.

Act as in-house tax counsel to Marriott's various business units.

Formulate Marriott's tax position documentation policies and procedures.

Ensure Marriott's compliance with the FASB 109 and FIN 48 requirements.

Communicate complex tax issues to non-tax team business members in a clear

and demystified manner. Forge strong relationships with internal customers

by partnering with all areas of legal, business development, business

operations, and corporate finance in order to enhance the linkage between

business objectives and tax strategy to achieve the optimal tax/business

outcomes.

Internal Revenue Service, Office of Chief Counsel

Associate Chief Counsel (International)

Attorney-Advisor, November 2004 to October 2007

Furnished technical information, advice, and assistance in the development

and drafting of tax legislation affecting the Internal Revenue Service and

related matters, specifically in the subject areas of transfer pricing,

domestic sales corporations, foreign sales corporations, extraterritorial

income exclusions, and electronic commerce issues. Participated in the

drafting and review of committee reports relating to tax legislation.

Initiated, developed, and drafted regulations, revenue rulings, and other

interpretations of the international provisions of the Code. Administered

such provisions, including provisions for which precedents were not

established or with respect to which the issues were highly controversial

and sensitive. Devised novel approaches to situations for which no

precedent existed. Performed extensive research into the background

(including Congressional intent of statutory provisions as reflected in

Congressional hearings, committee reports, court decisions, etc.) of the

international provisions of the Code. Served as the Service's technical

expert on the transfer pricing documentation requirements and its related

penalties, interest charged domestic sales corporations, and Section 936

restructuring Tier 1 issues.

Internal Revenue Service, Office of Chief Counsel,

Large and Mid-Size Business Division, Area 1 - Manhattan, NY

Senior Attorney, March 1999 to November 2004

Represented the IRS Commissioner in litigation before the United States Tax

Court with all aspects of corporate tax litigation. Provided legal advice

to the IRS revenue agents and officers in connection with the Service's

audits of large and mid-size businesses to assist with tax administration.

Served as Life Insurance Associate Industry Counsel and advised the

Life Insurance Technical Advisor with all issues regarding the taxation of

life insurance companies. Coordinated with Service Centers, the

Examination Division, and the Appeals Division in the resolution of legal

issues relating to IRS policies and procedures. Assisted Special Trial

Attorneys with complex tax litigation by researching all aspects of Federal

tax law, drafting court documents, conducting examinations and depositions

of witnesses, and analyzing settlement options. Reviewed refund suits

filed in Federal Court and prepared defense letters for the Department of

Justice, Tax Division advising of the Service's legal positions, potential

jurisdictional issues, and recommending courses of action. Established

appropriate liaisons with other Federal, state and local government

agencies.

State of Connecticut Superior Court

Judicial Clerk to the Honorable Linda K. Lager, September 1998 to March

1999

Analyzed and conferred with Judge on cases coming before session.

Performed legal research. Scheduled pre-trial motions and hearings.

Recorded and documented court proceedings.

Massachusetts Superior Court, Suffolk County

Judicial Intern to the Honorable Charles T. Spurlock, Fall 1998

Analyzed and conferred with Judge on cases coming before session.

Performed legal research. Drafted motions, memoranda, findings of fact and

conclusions of law, jury instructions, and proposed judicial opinions.

BAR MEMBERSHIPS

Connecticut, admitted November 1998

New York, admitted January 1999

U.S. Tax Court, admitted April 1999

OTHER SKILLS

Proficiency in Computer-aided Research, Microsoft Word, PowerPoint,

Visio, and Excel.

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