Tax Sr Mgr (international/M&A). Tax research/writing. Supervised staff
Resume:
Tyler L. Stone, JD MBA
Salinas, California 93109
************@*****.***
CA Bar License #308519
EXPERIENCE
Independent Contract Tax Work Irvine, CA
Independent Contractor for Controversy/Voluntary Disclosure Matters August, 2019 – March, 2020
Performed tax research and drafting of memoranda for small companies and individuals in technical and plain speak.
Dealt with IRS on technical tax issues and audits and spoke with the IRS and clients, respectively, on a regular basis to assure compliance with the IRC and Regulations, and to assuage any anxiety clients may have about the matter (and what they are doing now to be in compliance prospectively).
Alvarez and Marsaltaxand San Jose, CA
Tax Senior Director November 2018 – January 2019
\Performed ax research and drafting of memoranda and/or client emails detailing in technical or laymen’s terms (as appropriate) complex US international tax, relevant foreign tax, US federal and SALT domestic tax income and indirect tax issues.
Tax reform provision preparation, including Sections 965, 951A and Section 59A, keeping in mind the M&A plans of our clients.
Ernst & Young San Francisco, CA
Tax Senior Manager January 2017 – October, 2018
Extensively worked with both emerging and well-established tech companies for IP alignment and M&A activity focusing on international tax-free IP transactions and entity reorganizations.
Managed the research, drafting and second partner review of complex opinion letters and transactional structuring
Audited and prepared several transition-tax inclusions with teams of two to twelve lower level staff.
Prepared forward looking models and strategies with respect to the FDII, GILTI and BEAT additions to US the tax code.
Worked extensively with the transfer pricing group during functional interviews and valuation modeling.
Worked extensively with EY professionals globally to strategize internal restructurings and third-party M&A post TCJA.
Led several IRS and foreign tax authorities’ audits and responded to information document requests and additional controversy preparation as needed.
Participated in meetings and presentations with high level executives to explain and illustrate potential solutions and pitfalls of varying strategies.
RSM San Francisco, CA
Tax Senior Manager July, 2013 – December, 2016
Extensive research and preparation of client materials (including in-person presentations to top executives and Board of Directors) on U.S. International tax planning, including investment, exit, operational strategies, repatriation planning and IP alignment on behalf of corporate and investment fund clients.
Heavily involved in transfer pricing functional analyses and extensive IRC Section 482 compliance planning, in conjunction with the transfer pricing team.
U.S. foreign tax credit planning and operational consulting, focused on maximizing tax efficiency abroad, as well as on a US federal and US SALT level.
Top-side investment structuring for investment funds with US and foreign individuals, partnerships, corporations and exempt organizations to accommodate investors with varying tax concerns in preparation of an exit strategy with respect a potential deal.
Identified tax planning activities for existing clients, prepared memoranda and presentations pertaining to the legal and procedural requirements of such activities.
Engaged in extensive tax planning with tech corporations as well as private equity, real estate, hedge, venture capital and fund-of-funds investment firms. International tax planning and compliance for key stakeholders in such organizations with respect to their U.S. and international tax requirements.
Assisted clients with basic controversy matters and responding to the IRS and foreign taxing authorities as needed.
Burr Pilger Mayer San Francisco, CA
International Tax Manager August, 2011 – April, 2013
Managed and trained international tax staff on fundamental planning issues (such as the check-the-box regulations), and worked with federal tax staff on complying with U.S. informational reporting requirements.
Reviewed and advised foreign individual tax clients with respect to legislative changes.
Deloitte Tax San Francisco, CA
Senior Consultant (SALT, International and M&A Transaction Services Tax) January, 2007 – March, 2011
Developed models to determine future earnings and the potential impact such earnings may have on tax attributes of a target.
Conducted due diligence related to acquisition targets covering all tax aspects of their business.
Prepared structuring step plan presentations technical memoranda detailing the tax efficient structuring of domestic and international reorganizations and third-party transactions.
Extensive preparation and review of US Federal, SALT and international tax compliance forms.
TRAININGS ATTENDED AND INSTRUCTED
Participant in the RSM Sub C/M&A academy as well as the global international tax training academy in the Netherlands.
Participant in annual training conferences while at Deloitte, RSM and EY.
Instructor at EY annual training conference for senior associates devoted to the anticipated provisions of the TCJA.
Instructor for regional RSM offices with respect to US filing reporting requirements for foreign corporations, partnerships, disregarded entities, hybrid entities, ex-patriots/in-patriots and occasionally more complex forms for PFICs and foreign tax credits, etc.
EDUCATION
University of San Francisco (Joint degree program)
School of Law Juris Doctor 2006
oCALI Award for Excellence in Securities Regulation
oAssociate Business Editor on Maritime Law Journal
Masagung Graduate School of Management Masters of Business Administration 2006
University of California, Santa Cruz, CA Bachelor of Arts 2003
B.A. in Economics/Business Management with Honors and B.A. in Legal Studies
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