Management Tax
Resume:
Michael A. Falaguerra
Pawling, NY *2564
*****************@*****.***
SUMMARY
Attorney and CPA with varied domestic and international tax experience
involving research and planning; domestic and international audits and tax
compliance; tax accounting, provisions and reserves. My responsibilities
have included organizational tax planning and tax efficiency; direct
interaction with, and management of, external consultants for compliance
and tax planning; global compensation matters; permanent establishment
issues; federal, state international tax compliance; consulting to all
levels within the organization; working knowledge of APB 23 and 24, FIN 48
and ASC 740; and management of US and foreign country audits. My
experiences have included international and domestic strategies to lower
the effective tax rate; develop positions to avoid or reduce tax reserves;
management of large case IRS audits, fast track appeals and a long term
permanent establishment competent authority case in India; direct
interaction with Senior Management, business owners, legal department and
other corporate headquarters functions; document review; management of and
interaction with external consultants; permanent establishment analysis and
planning; tax risk management; preparation and review of domestic and
international tax compliance including the management of outsourced
compliance; establishment of SOX procedures and subsequent testing;
transfer pricing analysis and planning including an APA; preparation and
review of tax provisions and tax forecasts; VAT and other above the line
tax issues; partnerships and forensic tax review and remediation.
PROFESSIONAL EXPERIENCE
Hess Corporation, New York, NY
09/11-12/14
Tax Counsel
. Dedicated Tax Counsel seconded to an energy trading division of Hess
with over $35 billion in annual revenue and offices in the US, UK,
Switzerland and Singapore.
. Client Consulting - provided tax advice to traders with respect to
direct and indirect taxes for tax implications of trading energy
products or opening offices in new jurisdictions.
. Document Review - analysis and review of all counterparty
agreements.
. Tax Compliance - prepared international tax filings for GST and VAT.
Reviewed all state indirect tax filings.
. Audits - managed various domestic and international tax audits.
Interpublic Group Inc., New York, NY
12/04-09/10
Director and Tax Counsel - International Tax and Special Projects
. Senior Tax Counsel of a multinational advertising group reporting
to SVP - Global Tax.
. Restatement - collaborated with external consultants to analyze
all tax issues in a global company earnings restatement; managed a
five-year remediation of such tax issues involving tax structures
and compensation schemes with external counsel in over 30 foreign
jurisdictions including the development of substantial authority
positions to reverse a significant portion of the restatement tax
accruals.
. Global Compensation Issues - developed an expertise in global
compensation matters for world group subsidiaries with direct
reporting to a Senior Management Committee. Responsible for
identifying or responding to compensation issues and partnering with
financial and business executives to provide comprehensive tax
technical and process solutions.
. Sarbanes Oxley - department liaison for transfer pricing
analysis, development of procedures and subsequent testing and
documentation.
. Latin America - dedicated tax counsel to controllers group for
above the line tax issues.
. Tax Provisions - team support for year-end tax provision
including review of 275 separate subsidiary
audit reports for all tax issues and advice on specific issues
involving FIN 48 and ASC 740.
. Client Consulting - partner with CFO's, controllers and business
unit managers of global advertising subsidiaries for various matters
including locally managed audits, transactions and compensation
issues.
. Tax Compliance - reviewed US consolidated tax return, state tax
returns and partnership tax returns. Analyzed transaction reports
for tax return disclosure requirements and prepared all disclosures.
. Transfer Pricing - managed function for three years with two
direct reports; dedicated counsel to
function for additional three years; managed global tax audits;
managed an APA and analyzed various special project issues.
MasterCard International Inc., Purchase, NY
3/98-12/04
Vice President - International Tax
. Senior international tax position reporting to SVP of Global Tax.
Managed international tax function for a multinational corporation
with offices in 40 countries and revenues from 160 countries.
Supervised a team of 5 tax professionals located in New York,
Belgium and Singapore. This position involved extensive worldwide
travel.
. Tax Planning - responsible for reducing MasterCard's effective tax
rate and current tax liability by providing tax advice on domestic
and international issues and transactions and pro-active tax
planning.
. Audits - managed international audit issues for IRS large case audit
including competent authority case and IRS fast track appeals
issues. Managed international audits in India, Kuwait, Japan and
Belgium. International audit cases involved primarily permanent
establishment issues including a 5 year US/India competent authority
case. IRS audit issues included foreign tax credits, US
implications of permanent establishment issues and challenges to a
Foreign Sales Corporation.
. Compliance - reviewed the US consolidated income tax return and
managed all international tax aspects of the return including
5471's, subpart F, Section 956 and tax credits. Managed service
provider for compliance with all international tax filing
requirements.
. Tax Provisions - assisted in the preparation and management of the
quarterly and year-end tax provisions. Prepared tax reserve and
effective tax rate analyses and also quarterly tax forecasts all of
which required a clear understanding and implementation of FAS 109.
. Transfer Pricing - managed the transfer pricing system for
MasterCard and 40 foreign subsidiaries.
. Other Taxes - responsible for the identification and management of
non-income tax issues including VAT and GST.
. Client Consulting - lead consultant to legal, finance and business
units for various tax issues.
PolyGram Holding, Inc., New York, NY
5/94 - 3/97
Vice President & Tax Counsel
. Senior Tax Officer for the North and Latin Americas region of
PolyGram records and films reporting to the SVP of Global Tax.
. Management - organized and restructured the U.S. tax department
including implementation of substantive and administrative tax
policies, integration of the tax department function into the US
headquarters and record label operations while increasing the number
of tax professionals from three to ten.
. Tax planning - focused on the establishment of multiple partnerships
in the record and movie divisions including the Sundance cable
channel and Rocket Records. Participated in due diligence on US
acquisitions.
. Compliance - reviewed the US consolidated income tax return, all
state income tax returns, all sales and use tax returns and all
related estimated tax payments.
. Audits - managed the IRS large case audit and multiple state income
and sales and use tax audits, including quarterly meetings and
updates to global CFO and US CEO.
. Administrative - prepared budgets and managed all external
consulting engagements.
. Tax Provisions - reviewed quarterly and year-end information for
consolidation into global tax provision.
INCO Limited, New York, NY
1/91 - 5/94
Senior Tax Attorney
. Research, writing and tax planning for a multinational corporation
with extensive U.S. and foreign operations. Reported to the
Director of U.S. and Foreign Taxes with an emphasis on operational
and transactional planning for U.S. and foreign subsidiaries and
business ventures.
. Supervised and coordinated efforts of outside foreign counsel in
connection with various foreign jurisdictional tax issues.
The Pittston Company, Greenwich, CT
11/86 - 12/90
Tax Attorney
. Research, writing and tax planning for diversified Multinational
Corporation in the federal domestic, foreign and state areas
reporting to the Vice-President of Taxes.
Texaco Inc., White Plains, New York, NY
7/85 - 11/86
Tax Analyst
. Tax basis analyses for newly acquired Getty subsidiaries.
KPMG Peat Marwick, Stamford, CT
9/82 - 7/85
Senior Tax Specialist
. Preparation and review of corporate, partnership and individual
federal and state returns including consolidated returns in multiple
industries. Researched various federal and state tax issues.
EDUCATION
University of Bridgeport, College of Law, Bridgeport, CT
LL.M. in Taxation, Summa cum Laude
Syracuse University, College of Law, Syracuse, NY
J.D.
Bryant College, Smithfield, RI
B.S. in Business Administration, Major: Accounting, Summa cum Laude
Proficient in Microsoft Word, Excel and Power Point and tax
research systems. CPA (not active).
Contact this candidate