J. Michael Pusey
*** *. ********* **., ***. ***
Los Angeles, CA 90004
310-***-****; ****@******.***
Employment and Professional Career
Summary: I have executive experience with listed companies known for
excellence in
management. I was promoted to V.P. status at a NYSE financial
institution, and helped a NYSE government
contractor integrate a global services group in a remarkably
short time. As a tax and financial consultant or executive, I
have helped clients save millions in tax, and helped the CFO
improve the controllership function. I helped Grant Thornton
improve their reputation for international tax expertise and
served many years as top technical staff to their national tax
partner. I have authored or contributed to four tax books,
often write or edit for a fee, and often do tax research for
attorneys or other CPAs. I am experienced in tax research and
defense in practically all areas of tax, including international
and domestic, for-profit and non-profit.
I am an expert in planning dispositions of appreciated assets
via charitable remainder trusts and planning major gifts. I
have extensive merger and acquisition experience and have worked
in many different industries. My academic and professional
credentials include an award for high grades on CPA exam, core
courses through the Ph.D.in Business Administration with an
emphasis on accounting and minor in management, and co-authoring
an AICPA Tax Study. I can help establish an environment of
excellence in your tax department.
.
1986- Sole practitioner CPA, Accounting, Finance, Tax Consulting
Present 606 N. Larchmont Bl., Ste. 210
Los Angeles, CA 90004
May 2007- Interim Sr. Tax Accountant (sole divisional tax
representative)
July 2008 PAE Government Services, a Lockheed Martin Company
888 S. Figueroa St., #1700
Los Angeles, CA 90017
March 1981 Vice President, Assistant Tax Director
Dec. 1985 Great Western Financial Corporation, NYSE
Chatsworth, CA 91311
Salary mid 60's.
1974- National Tax Department
1981 Grant Thornton & Co., middle-market and listed companies
emphasis
Chicago, Ill., Phoenix, Los Angeles
1972- National Tax Department
1974 Laventhol & Horwath, middle-market and listed companies
emphasis
Phoenix, Washington D.C.
1968- Sr. Tax Accountant and Auditor
1972 KPMG Peat Marwick
Midland, TX
As a sole practitioner CPA, I have done general corporate consulting,
including functioning as CFO, but the emphasis has usually been the tax
function.
My reviews of tax returns have resulted in millions of dollars in refunds
from amended returns, revised filing positions and planning strategies. My
practice is often oriented toward long-term projects, often working with
listed or larger companies, frequently assisting other professionals. I
often receive fees as writer or editor for tax publishers. I have at times
accepted employment arrangements for interim tax or CFO positions
I was the one-person tax department at PAEgroup.com, a global services
division of Lockheed Martin. This particular division was 99% foreign.
The position included the gamut of corporate tax responsibilities -
compliance (E&Y TRS system), planning, responding to IRS and state/local
examiners, and long-range forecast. There is heavy emphasis on FAS #109
accounting for taxes and FIN #48 compliance as to uncertain tax positions,
and liaison with some thirty foreign divisions and subsidiaries. The
division was acquired in 2006 for $600-700 million, and the basic charge
was to integrate this very complex private group into a NYSE environment.
The position entailed heavy work product responsibilities amidst creating
systems and coordinating policies with corporate tax management on the East
Coast. As was anticipated, the position ceased to exist in Los Angeles
after integrating the merger.
My responsibilities at Great Western, where I was promoted to V.P.,
included supervision of one manager, two staff (including an attorney) and
two secretaries. I helped build a new department from two to twenty
professionals. As Manager of Research and Planning for the 40 billion
company, I was responsible for tax strategy, including multistate planning,
forecasting of consolidated tax position, analysis and implementation of
major transactions, including banking transactions and three major mergers.
I was also responsible for the IRS Big Case Audit program.
My responsibilities at Grant Thornton included research and planning for
local or national clients, quality control of tax memos from US offices,
coordination of planning issues, liaison with IRS national office, training
and client publications (e.g., LIFO inventory booklet, analysis of new tax
laws), coordination of articles by partners, and publications for the AICPA
and trade association (e.g., Retail Merchants Association newsletter).
At the international accounting firm Laventhol & Horwath, I had many
similar responsibilities, and coordinated the firm's tax research files and
authored papers for submission to the staff of the Joint Committee as
advocate for hospitality industry. At L&H, I worked with Bill Raby, later
head of the AICPA's Tax Division who was asked to be head of the IRS. L&H
had listed clients but was particularly known for middle-market business
clients, and the hospitality, realty and entertainment industries.
In my early career, at KPMG, I worked extensively in tax but was also
senior on
certified audits for various industries. I also helped design and
implement a job order cost system for a manufacturer of plastic bearings.
Professional
Allred Award for high grades on CPA exam presented by Texas Society of
CPAs.
I have written numerous articles, perhaps fifty published articles and
pamphlets, on tax and financial topics, including partnership and
corporate tax. I have written or contributed to four tax books, mainly on
individual and estate tax: Co-author, AICPA's Tax Planning Techniques for
Individuals, Revised Ed, Charitable Remainder Trusts (self-published, 2000
page library), commentary chapters for Kleinrock (CCH),
guest editor of Arthur Andersen's 1999 publication, Tax Economics of
Charitable Giving, I have written various publications for CPAmerica and
other publishers and authored a business finance course for a college.
Education
I worked one year toward the Ph.D. in Business Administration at the
University of Arizona, with an emphasis in accounting and a goal of being
an accounting professor. I completed the core courses in accounting,
finance (including a course in public finance, the economics of taxation,
as well as Ph. D seminary on investments), marketing, management, and
economics. I graduated with honors (2nd in Business School) at Texas Tech,
BBA with a major in accounting) and went on to complete a Master of Science
in Accounting with a minor in management. My master's thesis dealt with
taxation of mutual funds. I was a member of an accounting fraternity at
Texas Tech.
Software
Microsoft Office, plus Lotus, Quatro, Wordperfect, Adobe, various tax
compliance
and research softwares, and various accounting softwares, particularly
Quickbooks and
Dynamics.
Accomplishments / Industries
Accounting, auditing and CFO projects: I worked under the general charge
of the CFO of a college/seminary to improve the controllership function, a
project that encompassed training, systems, liaison with auditors, as well
as regulatory and IRS matters. My work as a sole practitioner CPA often
involved complex accounting matters, frequently in conjunction with tax
matters. I have worked on audits of a broad range of industries, including
oil and gas (two NYSE companies), hotels, nursing homes, construction,
banks and savings and loans, manufacturing, and exempts. I continue to
take continuing education courses on GAAP issues. I was interim CFO of a
$300 million apparel group. At Lockheed Martin division, I had to
generally work with over-the-top adjustments and consolidation issues, and
there was heavy emphasis on FAS #109 accounting for taxes, including
foreign divisions and subsidiaries. As a CPA, I have done various FAS #109
and foreign tax credit expense allocation studies, including a two-year
engagement for a listed financial institution that resulted in refund
claims and changes in accounting practices valued at some $4 million. I
have worked rather extensively with accounting method change issues.
Corporate tax: As a sole practitioner CPA, I often worked on corporate
tax projects, including compliance, coordination of state reporting
following IRS settlements,
coordination of state and local exams, and writing position papers for IRS
exams.
My practice involved little individual tax preparation, although it often
involved complex tax issues affecting investors and business owners and
their companies.
International tax: I spent two years on international tax assignment with
Grant Thornton, helping this firm gain a reputation for international tax
expertise. I reviewed international tax course and worked on two foreign
tax credit articles for partners. At Great Western, I worked with
PriceWaterhouseCoopers to obtain a favorable transition rule as to foreign
tax credit limitations affected international finance subsidiary. As a
consultant, I have completed transfer pricing studies. I have attended a
course on expatriate taxation . I filed tax returns for listed
pharmaceutical company with foreign R&D subsidiary and complex foreign
ownership. I have planned U.S. realty dispositions for foreign investors.
At division of Lockheed Martin, there is heavy emphasis on foreign
taxation, liaison with foreign branches and FAS #109 and FIN #48 accounting
for foreign taxes, as well as some exam work, including transfer pricing
issues. I have traveled extensively internationally.
State and local tax: I developed state tax strategy with Great Western (40
billion company) as it grew to a multi-state company. I coordinated an
informal opinion on nexus for intangibles from committee at Multistate Tax
Commission. I filed a series of state returns for NYSE manufacturing
company and NASDAQ service provider, both entailing foreign dividends and
other international issues. In state and local, I have consulted with
clients on sales and use tax issues. I filed a series of amended state
returns for a listed manufacturer of circuit boards. On several occasions,
I have worked on state tax audits for listed companies, including personal
service companies. In one of those engagements, modeled a result
satisfactory to client and taxing authorities when
national accounting firm had run up a big bill without achieving a
settlement.
Partnership tax, ventures and professional service companies: At Grant
Thornton, I coordinated partnership tax issues in real estate,
entertainment and other industries. I also helped coordinate internal tax
and partnership agreement issues for this national accounting firm. I
published an article on the topic of partnership tax.
Tax audits: Extensive experience both at corporate level and with two
national accounting firms and as a sole practitioner. One project involved
planning for
a major film studio's loss limitation problem arising from merger of a
previously owned subsidiary, an engagement involving complex consolidated
return issues as well
as strategies involving intercompany allocations of expenses. I worked on
a position paper for a regulated utility and its nuclear facility on an IRS
challenge to its deduction for regulatory soft costs.
Mergers and acquisitions: I helped plan and implement three major mergers
at Great Western. I coordinated amortization of intangibles, including
retaining outside appraisals of intangibles. I have developed M&A
checklists and done loss limitation studies and planning for major movie
studio. At another major film/TV studio, I worked on IRS challenge to
timing of deduction for its investment in unsuccessful retail division. I
co-wrote an article on acquisitions of sports teams, which involved
amortizations of TV contracts and other intangibles. The Lockheed Martin
work has involved merger issues and the complexities of post-merger
integration. My expertise in dispositions via charitable remainder trusts
(capital gains by-pass trusts that are themselves tax exempt) involves
transactional planning, usually appreciated realty or stock, including
M&A contexts and corporate planning..
Compensation: At Great Western, I worked extensively with stock option
program and generally coordinated compensation issues. I prepared a policy
/ position paper on some twenty-five perks. At Grant Thornton, I
coordinated pension compliance checklist. I edited a 2001 training course
on pensions / IRAs.
Financial services: I have had several financial institution clients,
mainly smaller listed companies with small tax departments. This work
often involved analysis of accounting records and accounting for taxes,
including FAS #109 studies, as well as tax exams. I worked for a pre-IPO
financial services group including an NASD subsidiary, registered
investment advisor subsidiary, insurance brokerage, trusts, etc.
Completed tax planning assignments and promoted the company's reputation
for tax expertise.
Charities, foundations, and charitable trusts. In addition to
transactional planning for major gifts, I have worked extensively with the
philanthropic sector and am generally familiar with the exempt sector's
tax, regulatory and accounting issues. I have worked on several certified
audits of charities and a municipality.