Manager Tax
Resume:
NOEL ARGUELLO, C.P.A
Phoenix, AZ 85045
**********@*****.***
PROFESIONAL EXPERIENCE:
International Tax Director. ON Semiconductor Corporation, Inc. Phoenix, AZ (2010 – 2015)
oDirectly supervised twenty managers in tax administration and planning in Europe, Canada, and Asia.
oResponsible for the review and finalization of the foreign tax provision ASC 740, and training of personnel.
oDrafted the VA memorandum by reviewing past years’ performances and future forecasts.
oCalculated APB 23 including the summary of over sixty CFC E&P.
oReviewed foreign DTL/DTA and rolled forward balances in a yearly basis.
oImplemented tax planning in the areas of Subpart F income (contract manufacturing), Repatriation and Redeployment of cash, Intercompany Finance, Global Holding Company in Europe, implementation of the Consignment Model/Principal, and Hybrid (check the box) planning.
oEstimated tax savings of approximately one hundred million in Subpart F income.
oAdvised tax managers on entity rationalization, consolidations, and reorganizations.
oLead the Mergers and acquisitions team by reviewing and editing the Purchase Agreement, completing Section 338 election and formulated the Acquisition Structure.
oReviewed and approved foreign indirect taxes such as VAT and GST.
oReduced withholding taxes utilizing the tax treaties.
oParticipated in non-U.S. tax planning by consolidating NOL in Japan, establishing holding companies in Netherlands, and applying tax incentives for new operations in Vietnam.
oReviewed U.S./International Tax compliance- OFL, FTC computation, Forms 1118, 5471, 8858, and 8865.
oImplemented transfer pricing policies by reviewing annual reports prepared by outside advisors.
oEnsured that the compliance and implementation of the annual reports were at arm’s length standards based on the transfer pricing study.
oLead a major reorganizational tax plan that involved legal, outside advisors, treasury, and accounting.
International Tax Director International. Apollo Group, Inc. (Phoenix, AZ)(2009 – 2010)
oResponsible for all international tax functions and preparation of federal income tax returns with audit-ready work papers.
oWorked closely with foreign tax and accounting personnel to ensure that indirect taxes and tax compliance in all foreign jurisdictions were filed.
oMaximized the foreign tax credits by increasing foreign source income and the use of intangibles.
oAccountable for due diligence of foreign Mergers and Acquisitions including 338 election.
oCalculated the quarterly and annual tax provision under ASC-740 (foreign)
Tax Director, Walmart Stores, Inc. (Bentonville, AR)(2005- 2009)
oSupervised a team of tax managers in Canada, Mexico, Central America, Brazil, Argentina, Chile and Puerto Rico.
oSuccessfully decreased the tax in Mexico by 25% by introducing debt after the purchase of Walmart Central America.
oEnsured that business goals were aligned with the tax plan to maximize tax efficiency in the region.
oMonitored due diligence on potential acquisition targets, tax integration of newly acquired companies, and advised my supervisors in all tax matters.
oDeveloped and implemented Sarbanes-Oxley controls.
oTrained personnel on ASC 740 tax provision.
oReviewed global transfer pricing structure (contracts, fees, royalties, loans).
oCoached and mentored staff on Transfer Pricing standards.
oMonitored cash, repatriation (dividends), and outbound loans and equity.
oResponsible for correct application of FIN 48.
oReviewed local tax planning (flat tax Mexico, M&A Argentina, IOE Brazil, M&A, and reduction of legal entities in Central America, tax settlement with IRS Puerto Rico, tax audit, hybrid debt in Canada).
oHighly skilled in tax research – IRA, BNA, CCH, and IBFD.
oExtensive experience in local taxation, income taxes, credits, tax treaties, minimum tax, withholding tax, and indirect taxes.
Regional International Senior Tax Manager. Global SantaFe. (Houston, TX)(2004 – 2005)
oManaged several countries in Southeast Asia and Latin America for tax planning, implementation, and local compliance.
oReviewed bids and tax structure of foreign operations.
oReview foreign tax provision for several foreign jurisdictions.
Tax Manager / Tax Planner. Pride International, Inc. (Houston, TX)(1998 – 2004)
oTeam leader in charge of changing international entities for check the box purposes (Europe, South America, Asia).
oReviewed tax issues associated with third party and Intercompany contracts.
oSupervised U.S. Federal Income tax compliance of Controlled Foreign Corporations.
oParticipated in Planning & Implementation of Global Corporate reorganization and international mergers and acquisitions.
oActively collaborated with the ASC 740 tax provision team.
oExecuted tax models for drilling operations.
oReviewed 338 elections.
oPlanned and implemented taxation in host countries.
oPrepared memorandums for outbound Tax Planning IRC 367
oImplemented Transfer Pricing review of the third party study.
Federal and International tax senior. Arthur Andersen LLP. (Houston, TX)(1996 - 1998)
oInvolved in federal and international tax compliance and planning.
oDrafted statements of facts for transfer pricing studies.
Associate Accountant BDO Seidman LLP. (Houston, TX)(1993 – 1996)
oPrepared and reviewed U.S. corporate, partnership, and individual tax returns.
oCompiled Financial Statements (GAAP)
oParticipated in audits and analytical review, lead schedules, tax accruals, reconciliation
EDUCATION:
oMasters in International Business, University of St. Thomas (Houston, TX)
oB.B.A. in Accounting. University of Houston Central Campus (Houston, TX)
oCertified Public Accountant (State of Texas)
Other qualifications:
oBilingual (Spanish)
oMicrosoft Office
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