Attorney, International Tax Compliance
Resume:
WILLIAM A. BLAGOGEE
Alexandria, Virginia. 22315
Home: 703-***-**** Cell: 571-***-****
*********@*****.***
EDUCATION:
JD: American University-Washington College of Law, Washington D.C.,
May 2001
B.Sc., Economics And Accounting: George Mason University, Fairfax
Va., May 1993
Continuing legal Education; Over 200 credit hours of CLE courses in
international taxation, regulation of financial services products, and
taxation of cross boarder M&A.
OBJECTIVES: Assist Large to Mid-sized Corporations with foreign presence
comply with IRS and OECD rules and regulations and research effective tax
strategies for minimizing withholding and world-wide effective tax rates.
EXPERIENCES:
Law Firm of William A. Blagogee, PLLC
7/05 - Present
Attorney
Area of Practice: Taxation of Financial Services Products,
International Taxation & Real Estate Transactions.
Consulting Engagements include: Fannie Mae - 2006 Financial
Accounting Restatement for SEC reporting compliance; Delta/United
Airline Merger; Allied Waste/Republic Merger; Sunrise Assisted
Living,/Marriott Corporation - Analyzed tax gain or loss in
connection with the merger and consolidation of the entities; Calvert
Mutual Funds Corp - Analysis of Wash sales and loss harvesting strategies
to minimize income tax liability.
o Reviewed audited financial statements for compliance with FASB
statements 52, 91, 109, 114, 133, 140, 141(R) 157 and 160 in
connection with Fannie Mae's SEC restatement reporting obligations.
o Prepared and reviewed tax calculations on loan premium/ discount
amortization and related gain/ loss on sale of whole loans and
other investments.
o Reviewed interest rate swap arrangements and documentation for tax
qualified hedges.
o Prepared corporate and partnership tax returns and accompanying
schedules in compliance with IRS regulations.
o Computed and advised corporate clients with respect to tax
deduction for manufacturing activities.
o Prepared IRS Forms 2555, 5471, 5472, 8858, 1118 and information
returns of US entities with Subpart F income.
o Computed tainted subpart F income and elections to exclude subpart
F amounts; prepared E&P worksheets, determined foreign currency
gain/loss, and determined world-wide effective tax rates on
repatriated income.
o Computed Section 1248 gain on disposition of CFC stock and impact
of Section 338 election on qualified stock purchase; performed tax
reporting and analysis under IRC 367 outbound reorganization
o Assist Corporation with preparation of documentations in
negotiating Advanced Pricing Agreements.
o Computed Qualified Dividends, Analyzed wash-sales and capital gains
for book/tax discrepancies. Monitored tax compliance including loss
carry forwards, tax lot holdings and wash-sale reversals, ROCSOP
adjustments, tax foot notes and built-in-losses for mutual fund
companies under Sub Chapter M of the IRC.
o Prepared and reviewed tax work papers related to partnership
syndications for MBS, RICS, REITs and LIHTC.
o Strong knowledge of FAS 109 and FIN 48 tax audit and compliance
related matters.
o Developing technical skills in the area of financial services
products, specifically in SWAPS, CDS, CDOs, municipal bonds and
auction rate securities.
o Defended clients facing state sales and use tax, property tax,
unitary and franchise tax audits before tax agencies.
o Advised clients regarding state nexus issues in connection with
lease financing, M&A and disposition activities.
o Strong research, writing, and problem solving skills in federal,
state and international taxation.
Deloitte & Touche, LLP, Washington D.C.
Project Controller, Federal Government Contracts
2/04 - 7/05
o Managed federal contracts by providing pre and post award
compliance and legal support.
o Assisted in planning, budgeting, scheduling, monitoring, decision
analysis and other organizational issues.
o Developed cost price proposals and best accounting practices for
tracking direct labor and materials cost pursuant to the terms of
the contract.
o Tracked project finances to determine project revenue recognition,
profitability and net write-ups.
o Developed direct and indirect project cost analysis under fixed,
variable price and cost reimbursement contracts
o Working knowledge of FAR, DFAS, FASA, CAS and other federal
statutes dealing with commercial sales.
Taylor, & Rea, PLC., Fairfax, Virginia.
Attorney
Area of Practice: Taxation & Real Estate Transactions
6/99 - 12/03
o Drafted wills, trusts, and business succession planning documents
to administer estates and trusts.
o Prepared corporate, partnership and international tax returns,
including estimated returns, AMT, tax adjustments (schedule M-1, M-
2, M-3), NOL, consolidated returns, computation and allocation of
foreign tax credits.
o Assisted tax departments of multinational corporations comply with
IRS tax audit inquiries.
o Prepared memoranda of points and authority defending clients before
the IRS and state taxing authorities.
o Assisted in structuring cross-boarder transactions in compliance
with IC-DISC and transfer pricing regulations.
o Assisted in structuring real estate partnerships, acquisitions and
dispositions in compliance with IRS regulations.
o Prepared real estate acquisition and leasing documents, including
land sale documents and opinion letters.
o Performed due diligence for acquisition, development and
construction projects.
Metrocall Inc., Alexandria, Virginia.
5/98 - 5/99
Senior Tax Accountant
o Prepared and Filed corporate and partnership tax returns and work
papers.
o Prepared memos in defense of company's corporate tax deductions and
exclusions.
o Prepared and filed foreign corporation annual reports and business
registration forms.
o Prepared and filed state franchise tax returns, property taxes and
sales and use tax returns.
Allstate Financial Corporation Arlington, Virginia.
Funding Accountant 3/97 -
5/98
o Structured up to $5 million in bridge financing for small and mid-
sized companies.
o Performed due diligence on borrower's inventory, receivables and
debt ratios to determine borrower's liquidity.
o Evaluated credit and financial risk of new clients.
o Researched and drafted preliminary letters of credit for approval
by general counsel.
o Monitored borrower's liquidity ratios to alert general counsel to
advice borrower whether that constitute an event of default.
Bar Membership - United States Tax Court; District of Columbia Bar; Federal
Dist. of Maryland; Court of Veterans Appeal.
Association Membership
American Bar Association - international taxation, Property law and
land use, government contract, securities law and tort and insurance
sections.
Mount Vernon -Lee District Land Use and Transportation Planning
Committee.
Contact this candidate