Manager Customer Service

Richard Smith

***** *. ****** **., *******, AZ **044

Cell: 602-***-**** Home: 480-***-**** **********@*****.***

Tax Professional

Resourceful and intuitive tax manager respected for expertise on international and

domestic taxation. Resolved residency and withholding tax issues with foreign

governments. Managed taxpayer service operation in Paris France for expatriates.

Authored a tax guide for green card holders. Regarded as a hands-on manager who builds

strong team environments and fosters a sense of pride and integrity.

Competencies

Permanent establishment issues Expatriate issues

Foreign tax credits & Form 1118 Withholding tax issues

Advanced Pricing Agreements & Transfer pricing Residency issues

Tax treaty interpretation and application Check the box requirements

Forms 5471, 5472 & other international forms International reorganizations

Sources of income Subpart F income

Staff training, coaching, and mentoring Tax research software

Career Highlights

JDA Software Group Inc. ~ Scottsdale, Arizona 2008-2009

Tax Manager (employee and contract basis)

(JDA Software Group, Inc. is the world's leading supply chain solutions provider. JDA

has 23 foreign subsidiaries and sales totaling $390 million to over 5,800 customers in 60

countries.)

• Resolved US residency certification request problems and established new procedures

to ensure the timely receipts of foreign income with the proper withholding rates.

• Responsible for tax returns & all related forms, handled four tax audits concurrently,

prepared tax budget forecasts and managed two tax accountants.

• Established new procedures to ensure compliance for expatriate employees.

• Worked with employment tax staff to ensure the tax returns were timely filed and to

resolve tax problems for expatriate employees.

• Alerted management to potential permanent establishment issues in countries where

the company had employees.

• Reviewed tax department procedures for compliance with Sarbanes-Oxley standards.

• Worked on an acquisition of an international entity & a corporate restructure plan,

including adding the new expatriate employees into the companies system.

Internal Revenue Service

1971--2008

International Examiner Phoenix, Arizona 1987-2002 & 2006-2008

Conducted international audits of multinational companies, including four

•

simultaneous examinations with tax authorities of foreign countries. One set the

guidelines for all future examinations with the United Kingdom.

Richard Smith page 2

• Conducted successful transfer pricing and functional analyses. One case resulted

in an agreed adjustment in taxes due of over $1 million.

• Did subpart F computations and compliance examinations.

• Did detailed foreign tax credit examinations.

• Negotiated six Advanced Pricing Agreements with multinational entities.

• On-the-job coach for seven International Examiners.

Rewrote the international issues training material for International

•

Examiners, including sections on tax treaties, expatriate tax issues, and foreign tax

credits. Wrote and taught several classes on technical international taxation issues.

• Responsible for the first court case involving Formal Document Requests.

• Worked with counsel as a technical international tax advisor.

Deputy Tax Attaché – U.S. Embassy, Paris, France 2002-2006

• As the U.S. Competent Authority representative, I negotiated agreements with the tax

administrations of foreign countries.

• Negotiated the resolution of permanent establishment issues.

• Worked with the Luxembourg government to obtain information for a tax court case

on foreign tax credits. The information clarified who the responsible party is under

Luxembourg laws for the payment of taxes.

• Resolved withholding tax issues and Certification of Residency problems. One case

resulted in the refund of $1 million of taxes that were withheld for over nine years.

• Author of IRS Document 4588, a tax guide for green card holders.

• Advised foreign national executives on expatriate tax issues.

• Managed the customer service operation for U.S. expats and foreign national filers.

• A key member at meetings on tax and accounting issues at the OECD.

• Frequently requested to make presentations at meetings of corporate executives, tax

accountants, tax attorneys and expatriate taxpayers in Western Europe.

Assistant Int’l. Program Mgr. & Revenue Agent – Detroit/New Orleans 1971-1987

• Managed the daily operations of the New Orleans District’s international program

1975 to 1987. During this time period the program ranked as the most successful

program in the country.

• Team leader of audits of large multinational companies, including the examination of

the employment tax filings and the treatment of expatriate employees.

• Wrote and taught the first IRS training material on tax havens.

• Wrote statutory notices and worked with counsel on the preparations of cases for trial.

Education

• Foreign Service Institute, Alexandria, VA. (European Economic Studies)

• Air Force Officers’ Training School. (military and leadership training)

• B.B.A. Western Michigan University. (accounting major)

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