Tax Service
Resume:
JOYDEEP MITRA
Mamaroneck, New York 10543
Tel: 914-***-****
Email: ********@*****.***
EDUCATION
New York University School of Law, LL.M. in Taxation, May 2005.
London School of Economics and Political Science, LL.B., 1993.
University of Calcutta, Presidency College, Bachelor of Science in
Economics, 1990.
EXPERIENCE
KPMG LLP, M&A Group, New York March 2006 - Present
Performed research, planning and rendered advise on following: (i)
Corporate reorganization with emphasis on US and foreign provisions of the
Code; (ii) Incorporation of foreign branch operations with branch losses;
(iii) Acquisition and reorganizations involving S corporations; (iv)
Structuring tax efficient distributions under Section 956; (v) Assisted in
due diligence and researched issues relating to potential targets; (vi)
Advised clients on qualification for tax treaty benefits and various
compliance requirements (e.g., Form 1042, 8833, etc.); (vii) Researched
deductibility of interest provisions under US tax principles.
Ernst & Young LLP, Leasing Group, New August 2000-June 2002
York
Researched and wrote memoranda on structuring transactions including
following: (i) Defeasance transactions, US tax ownership rules, lease vs.
financing transactions and US tax depreciation rules; (ii) Intellectual
property transfers; (iii) Service contracts; (iv) Reviewed and drafted
responses to IRS information requests. (v) Researched issues on limitation
of benefits under relevant tax treaties.
Watson, Farley and Williams, Tax Group, September 1998 to July 2000
New York
Researched and wrote memoranda on tax aspects of transactions including
following: (i) PFIC issues; (ii) Acquisition and sale of US real property
by a foreign individual; (iii) Transfer of securities in a securitization
transaction; (iv) Debt-Equity issues of foreign securities offered to US
holders; (v) US trade or business issues on the operations of foreign
advertising firm and competent authority procedures under relevant tax
treaty; (vi) Researched issues on character of outbound payment streams and
their qualification for tax treaty benefits.
Coopers & Lybrand LLP, International Tax August 1996 to July 1998
Group, New York
Participated in various international tax projects, including: US tax
treatment of distributions from foreign subsidiaries; tracking tax pools
and E&P pools; reviewed information returns of foreign subsidiaries;
conducted presentations on foreign reorganizations and PFIC rules.
OTHER EXPERIENCE
Contract Attorney Positions (Pursued to finance LL..M. January 2003 - August
Program in Taxation) 2004
Reviewed financial data, corporate communications and corporate documents
on alleged accounting irregularities.
Pro Bono Consulting (Pursued while applying for permanent October 2005 -
positions) February 2006
Advised US private equity fund on US and local tax issues of investment
structures, including application of Tax Treaty rules, US anti-deferral
rules, and US net basis taxation.
ADDITIONAL INFORMATION
1. Naturalized US citizen
2. Bar Admissions: (i) New York: 1998; (ii) England & Wales: 1994; (iii)
India: 1993.
3. References: Available on request
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