ROBERT ERNEST GYE MANT, J.D. EN HANC I NG P ROF ITAB IL I TY T HROUGH I N TERNAT IONAL TAX

P LAN N I NG A ND F I NANCIAL OVERS IGHT

Lexington, SC 214-***-**** acu14h@r.postjobfree.com

Senior legal, tax, and finance leader w ith deep expertise in international and domestic real

estate, tax planning and customs t ransactions, SEC compliance, analysis, and research. Takes a

h ighly systematic approach to balance legal, finance, and accounting perspectives to solve complex

p roblems and mitigate r isk. Builds collaborative relationships with internal and external legal

compliance and government regulators to ensure compliance and negotiate favorable settlements.

O ffers a unique global, multi-cultural perspective across a variety of industries. Selected

a ccomplishments:

STRATEGIC L EGAL F INANCIAL PLANNING: P ROV I DED S TRATEGY F OR L EGAL E NT I TY R ESTRUCT UR I NG,

A ND

RE I T U N I T ED T ECHNOLOGI ES .

F OR MAT ION A ND S PI NOFFS F OR

Resolution of Tax Controversy : Resolved over $100mm in international tax exposure for

P rysmian Cables and Systems.

M &A RESTRUCTURING: P ROV I DED S TRATEGY F OR L EGAL E NT I TY R ESTRUCTUR I NG, RE I T

A ND F OR MAT ION

A ND S PINOFFS . D EVELOPED U N I T ED T ECHNOLOG I ES .

P LANS F OR I N VERSION O F R EAL E STATE E NT I T I ES F OR

Compliance: Ensured Investment Company Act of 1940 compliance for multiple clients.

Reviewed FINRA proposed rules as applied to real estate Master Limited Partnerships in

sales of securities on NASDAQ

Team Development : Mentored tax and FX teams on planning and international compliance

solutions.

U nique Expertise that Delivers Business Success

Regulatory Compliance

Leadership Mentoring

SEC SOX ASC740 FIN 48 FAS

In ternational Tax Strategy

109

Cash Flow Optimization Forensics

Risk M it igation

Joint Ventures Investments

Cross-Border Controversies

M &A IPO Restructuring

IRS GAAP IFRS FINRA

Divestiture

Bi-lingual Spanish-English

Real Estate REIT

A T rack Record of Legal, F inancial and Ethical Results

A DAMS GYEMANT GRIFFI N A DVISORY GROUP, L EXINGTON, SC 2013- PRESENT

ADV ISORY 1031 EXCHANGES

GROUP A ND CONSULT ING F IRM F OCUSED O N R EAL ESTATE TAXAT ION W IT H A N E MP HASIS O N A ND

A DV IS ING C LIENTS O N STATUTORY C HANGES

CL IENT : A REED E LSEVIER, PLC

SUBSIDIARY OF

D EVELOPED 1031 E XCHANGES. ANALYZED BPA

S TRATEGY A ND T ACT ICS T O H AN DLE E F FECT O F N EW

D ECE MBER 2015 I N I RS T EFRA

L EG ISLAT ION I N PARTNERSH I P A UD I TS B Y AGENTS A ND C HANGES I N L AWS

D UE T O N EW L EG ISLAT ION .

D EL I VERED S OLUT IONS F OR T AX T REATMEN T O F C OSTS A ND I MPACT O N I NS I DE /OUTSI DE BASIS O F I N VESTORS .

CL IENT : U NITED T ECHNOLOGIES CORPORATION, F ARMINGTON, CT

P ROV I DED S TRATEGY F OR L EGAL E NT I TY R ESTRUCT UR I NG, RE I T F OR MAT ION A ND S PINOFFS . D EVELOPED

P LANS F OR I N VERSION O F R EAL E STATE E NT I T I ES .

ANALYZED E XPOSURE I N R EPATR IAT ION O F PARTNERS /M E MBERS I NCO ME F RO M O FFSHORE E NT I T I ES .

P rysmian Cables and Systems, U.S., I nc., Lexington, SC

2011-2013

$13B manufacturer of high-power cables for utilities, telecommunications and related industries, with global

headquarters in M i lan, traded on M i lan and London exchanges

Recruited to lead resolution of over $80mm in exposure of global tax liabilities.

D I RECTOR OF TAXAT ION NORT H AMER ICA

Led tax operations for U.S. HQ, a team of tax professionals. Provided oversight to U.S. and

Canadian subsidiaries and cash/pool entities. Coordinated relations with B ig 4 tax advisors and

i nternational counsel. Provided oversite of W2, 1099, and comparable European filings. Oversaw

business tax licensing in 50 states. Served as t rusted advisor to U.S. and I talian executive teams

regarding tax planning for new ventures, real estate acquisitions, M &A activity and expat policy.

Led disposition of closed manufacturing facilities in NA and UK.

Resolved $80mm tax exposure with successful completion of 2008-2010 IRS examinations.

Resolved $25mm tax exposure to t ransfer pricing in coordination with third-party KPMG

advisors.

Resolved multiple local country issues in German Republic and U K and Department of

Revenue sales and Use audits in South Carolina and Florida.

Directed Canadian provincial and federal income tax filings and passed audits by tax

authorities.

Eliminated $2.2mm in IRS penalties for 5472 filings.

Provided expatriate legal/tax advice. Directed VAT examinations, in collaboration with

foreign Counsel and PwC.

Resolved FBAR delinquencies to avoid substantial penalties.

I ndependent Consultant, Dallas, TX and San Jose, Costa Rica 2009-2011

Multiple assignments for U.S. and Costa Rican corporate legal/ tax projects including:

Grant Thornton : Provided t ransfer pricing and negotiation of MAP for U.S. based global

entities. Ensured Investment Company Act of 1940 compliance for multiple clients. Reviewed

F INRA proposed rules as applied to real estate Master L imited Partnerships in sales of

securities on NASDAQ.

Multi-national Manufacturers : Oversaw section 1031 exchanges by investors in REITs. FRCP

compliance, FBAR compliance, insurance and Risk Management regulation matters.

U.S. Timberland Investment Fund : Legal counsel for biodiesel real estate project in concert

w ith U.S. and Costa Rican counsel, serving as an advisor President Chinchilla of Costa Rica.

Multinational manufacturer : Advisor on Mexico real estate tax matters. Resolved tax

compliance issues in Baja California for maquiladora operator.

Investment Bankers: Provided FX hedging advice and contracts review oversight. Prepared

t ransfer pricing study for bilateral t ransfer pricing agreement with U.S. and Mexican tax

authorities.

L ighting Science Group Corp, Dallas, TX 2007-2009

Publicly-held manufacturing company with plants in five countries and four states.

Company was aggressively pursuing multi-national acquisitions and needed compliance

p lanning and strategy as well as ensuring compliance with new SEC guideline around

l ighting regulations.

D I RECTOR OF F I NANCE AND TAX

Directed U.S., state, local, and foreign taxation filings and resolution of disputes with tax

authorities. Resolved real estate matters resulting from EPA issues. Addressed maquiladora tax

matters in Mexico real estate, including effects upon U.S. taxation in consolidated tax returns.

P rovided comprehensive coordination with external auditors. Mentored and supervised 20 tax

p rofessionals in US, EU, Mexico, Japan and Australia, as well as Treasury and FX hedging and

p lanning teams.

Implemented software system for indirect tax compliance with parent and subsidiaries.

Designed supply chain management procedures to mitigate customs and cross-border issues.

Provided M &A advice in 5 cross-border t ransactions with U.S. reporting entity.

Reviewed consolidated tax returns for both domestic and international filings in Canada,

Mexico, EU, and Japan along with FAS 109(ASC 740) and preparation of FIN 48 procedures and

compliance.

Ensured SOX 404 policies and procedures compliance and resolved FAS 157 issues.

Participated in 5 acquisitions within a 9-month period, directing SEC filings and compliance.

T atum Pa r tners and Accretive Solutions, Dallas, TX 2007

Leading professional and interim services firms

Contracted to provide technical tax and legal support for multiple private, pre-I PO multi-

national manufacturing startups.

I N TER I M SEN IOR MANAGER

Addressed real estate securities issues. Ensured compliance with FAS 142, FAS144, FAS 157, and

SOX. Implemented internal control process improvements and IFRS conversion reporting with

national consultants and external auditors from Deloitte.

Resolved issues with lenders and institutional investors on indirect tax compliance.

Coordinated with outside counsel on Mexico i r regulari ties in payroll taxes and conducted

I FRS research with Mexican and U.S. GAAP.

Built and mentored tax reporting employee group to manage income, state and local tax.

Resolved limited partnership taxation issues with multilevel ownership and goodwill audits.

T r io I ndustries Group, I nc., Dallas, TX 2000-2006

Early-stage publicly held manufacturer of construction materials uti lizing DuPont proprietary coatings

technologies, including development of patents and l icenses

Recruited to develop international tax and real estate strategies.

D I RECTOR OF F I NANCE AND TAX, COUNSEL

Coordinated partnering in Europe and Latin America, coordinating with tax departments of defense

contractors. Provided oversight for U.S. Treasury/FX issues. Directed strategic r isk management

p lanning with Marsh.

Directed multiple divestitures and split-offs of real estate properties valued at over $100mm.

Developed and implemented tax compliance strategies to meet Department of Defense

requirements.

Responded to new SOX 404 regulations by conducting an in depth study of business impact

w ith Big 4 fi rm.

Provided consulting on Costa Rican sustainable forestry initiative, including sale of

substantial acreage to U.S. timber hedge funds, managing college endowments and providing

advice on tax and securities compliance.

T r inity River Capital Ventures, Dallas, TX 1999-2003

Equity venture capital fund created by local oil investors dealing with real estate and technology opportunit ies

GENERAL COUNSEL

A dvised investor group on real estate and technology opportunities in Texas, California, and New

York. Provided tax and legal advice in coordination with Texas counsel.

E arly Career Experience

Gyemant Law Fi rms P r ivate Practice, San Francisco and Los Angeles.

General Counsel: Tax, I PO SEC reporting and compliance, A dvanced Micro Devices, Inc.,

Sunnyvale, CA

Associate in SEC and tax practice, complex real estate ventures, O r rick, Her r ington &

Sutcliffe, San Francisco, CA

Senior Tax Accountant and Manager, E rnst & Young, Oakland, California

E ducation a nd Credentials

J .D., U niversity of California, Berkeley School of Law, Cum Laude

California Law Review. 3.95 GPA

A.B., Accounting and Liberal Arts double major, U niversity of California, Los Angeles, Cum

L aude

Member of the Bar, New York.

Member of the Bar, California.

Admitted : US Tax Court, various federal courts.

Certified Public Accountant, CA. Passed all parts in one sitt ing (Inactive)

AICPA member

CGMA designation

Technical Expertise

ERP systems: SAP, PeopleSoft, Lawson, Oracle, SQL (Great Plains), Hyperion

Treasury software

Tax research software: RIA, CCH

Tax software Vertex, Tax Stream, Pro Systems, Corp Tax, One Source.

MS Office

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