Richard K. Friedrich

**-** *********** ****. **** A-57

Forest Hills, NY 11375

(Mobile) 347-***-****

(E-Mail) adxv8x@r.postjobfree.com

EXPERIENCE

Consultant To Price Waterhouse Coopers, Inc. (December 2020-Present)-This position allows for the provision of international tax advice to non-Price Waterhouse Coopers, Inc’s clients.

• Provide international tax advice to the firm’s clients who are engaged in private equity, funds (private and public);

• Transactional analysis of both inbound and outbound transactions;

• Review of opinions and technical memorandums drafted by employees of the firm;

• Review of U.S. and foreign filing requirements for foreign subsidiaries of firm’s clients; and

• Review for Form 5471s.

Private Practice (February 1, 2017 to Present)

• Popular Bath Products, Inc.—Created, implemented and currently manage the company’s international legal structure. Advise owners concerning proposed transactions, new foreign/domestic tax law changes, review all foreign transactions to confirm compliance with current legal structure and intercompany agreements, draft all intercompany agreements, manage all domestic and foreign tax compliance, manage foreign legal advisors. Provide United States income tax compliance for foreign legal entities. Assist Chief Financial Officer and Chief Operating Officer on special international projects.

• Barnett Corporation—Created, implemented and currently manage the company’s international legal structure. Provide tax due diligence on proposed acquisitions. Draft Board Resolutions for both domestic and foreign legal entities, loan agreements and intercompany service agreements. Manage company’s banking relationships relevant to foreign legal entities. Provide the company’s management with advice concerning trading activities. Manage and document the company’s compliance with intercompany transfer pricing agreements. Manage the company’s relations with both the Internal Revenue Service and foreign taxing jurisdictions. Provide United States international income tax compliance for foreign legal entities.

• Brian Perkis & Associates CPAs—Provide international tax advisory services and United States income tax compliance for foreign legal entities.

• Anglis & Associateds CPAs—Provide international tax advisory services and United Stated income tax compliance for foreign legal entities.

• Nadine Plaut, CPAs—Provide international tax advisory services and United States income tax compliance for foreign legal entities.

DDK & Company LLP (July 18, 2015-February 1, 2017)

• Created, implemented and managed legal structures for clients who intended to expand their business operations outside of the United States;

• Advised expatriates and non-resident aliens concerning their tax obligations in the United States and their resident countries;

• Conducted internal international tax training classes (CPE creditable); Richard K. Friedrich Page

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• Reviewed current and prior international tax compliance for quality control purposes; and

• Provided technical memorandums to support client’s tax positions. Private Practice (July 1, 2013 to June 30, 2015)

• Tax lead for merger and acquisition transaction (both from a buyer’s and seller’s perspective). Focused acquisitions in Asia and South America;

• Created, implemented and managed legal structures utilized to acquire targets in a tax efficient manner;

• Reorganized acquired targets to generate low taxed income, enable the redeployment of earnings without triggering adverse tax consequences, and enable the client to significantly decrease their worldwide effective income tax rate;

• Advised client’s joint venture partners (both domestic and foreign) regarding acquisition legal structures and post-acquisition restructuring (where necessary);

• Reviewed post-acquisition transactions to ensure compliance with the agreed to international tax planning proposal (to insure that the tax results proposed were achieved);

• Drafted Merger & Acquisition Report for the client and the client’s legal advisors; and

• Drafted examples of legal documents (for client’s legal counsel) that are required for a proposed transaction.

Marks, Paneth LLP (f.k.a. Rosenberg, Neuwirth & Kuchner, P.C.), New York—Director of International Tax Services (January 2010 to July 1, 2013)

• Develop and market the firm’s domestic and international tax practice (current book valued at approximately $500K);

• Act as in-house international tax resource to corporations, law firms and public accounting firms;

• Provide tax advice to non-U.S. persons investing both within and outside of the U.S.;

• Create, implement and manage sophisticated international tax plans; and

• Manage the firm’s international income tax compliance engagements. Marcum LLP, New York—Senior International Tax Manager (January 2009 to January 2010)

• Created, implemented and managed an international tax consulting practice in the New York office;

• Teamed with Marcum—Rachlin LLP (a division of Marcum LLP) in Florida to develop their international tax consulting practice;

• Provided sophisticated international tax planning opportunities to entrepreneurs, high net worth individuals (both U.S. and foreign), and mid-market level companies (both public and private);

• Acted as international tax resource to both public accounting and law firms;

• Managed the firm’s international tax compliance service line;

• Lead international tax roundtables within the firm; and

• Conducted international tax seminars for tax professional organizations. Deloitte Tax LLP, New York-Senior International Tax Manager (May 2006-December 2008)

• Provided FIN 48 international tax technical audit review to Fortune 100 companies;

• Member of merger & acquisition team providing international tax advice to private equity firms;

• Managed in-bound acquisitions for non-U.S. clients;

• Provided international tax advice to Fortune 100 clients concerning their global initiatives;

• Managed non-U.S. tax audits;

• Managed quality control review of international tax compliance engagements; and

• Managed local country offices’ participation in global planning initiatives for Fortune 100 companies. International Tax Consulting, (Private Practice May 2004-May 2006)

• Provided international tax planning and compliance support for middle market companies;

• Advised senior management on both tax and non-tax issues concerning international expansion;

• Implemented and managing foreign organizational structures;

• Managed the international tax due diligence for new foreign acquisitions; and

• Provided international tax audit defense.

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Best Buy Co., Inc.-Richfield, Minnesota-International Tax Manager, (April 2002-May 2004)

• Responsible for the creation, implementation, and management of all foreign ownership structures for Best Buy Co., Inc.’s subsidiaries (i.e., Best Buy Enterprise Services, Inc.; Best Buy Canada Limited; Best Buy Business For Business; Best Buy For Government; and vpr Matrix, Inc.). Estimated net present value of the savings associated with these structures: $161M over a three-year period;

• Responsible for the creation, implementation and management of all domestic and foreign intercompany financing;

• Responsible for the creation and implementation of the company’s Enterprise Shared Services Initiative. Annual tax savings: $8.4M;

• Responsible for the risk management associated with foreign currency transactions;

• Provided significant support (both tax and non-tax) to senior management in Canada, the People’s Republic of China, and the United States surrounding new business development;

• Taught legal entity accounting to Best Buy Co., Inc. Finance Department (700 employees);

• Managed one employee-International Tax Compliance; and

• Specific country experience: Bermuda, Canada, Germany, Hong Kong, Korea, Mexico, the Netherlands, the People’s Republic of China, Taiwan, and the United Kingdom. Sempra Energy-San Diego, California-Group Tax Manager-International, (November 1998-July 2001)

• Provided tax advice to senior management concerning international acquisitions and mergers on behalf of Sempra Energy’s subsidiaries (i.e., Sempra Energy International, Sempra Energy Trading Corp., Sempra Communications, Sempra Energy Resources, and Sempra Energy Solutions);

• Responsible for the creation and implementation of all foreign ownership structures;

• Responsible for the creation and implementation of all financing structures utilized to fund Sempra Energy’s foreign acquisitions;

• Negotiated tax rulings with foreign jurisdictions;

• Tax lead in all foreign joint ventures;

• Supervised all international tax compliance;

• Reviewed all inter-company and third party service agreements;

• Managed annual transfer pricing studies, and

• Specific country experience: Argentina, Canada, Chile, Denmark, Germany, Indonesia, Korea, Mexico, the Netherlands, Peru, Singapore, Switzerland, Spain, tax havens, United Kingdom, and, Uruguay.

Bank of America NT & SA-San Francisco, California-Senior International Tax Analyst, (October 1996-November 1998)

• Provided tax advice to the Bank’s subsidiaries/branches concerning proposed foreign transactions;

• Reviewed inter-company transactions with respect to compliance with Internal Revenue Code Section 482 and the Anti-Boycott Regulations;

• Wrote the anti-boycott section of the Bank’s Corporate Compliance manual.

• Coordinated the sale of Bank subsidiaries to third parties;

• Coordinated with Bank of America personnel to resolve income tax matters pertaining to withholding requirements, foreign tax credits, subpart F income, and the sale of foreign subsidiaries;

• Reviewed and determined the adequacy of the Bank’s foreign audit reserves and pension plans.

• Reviewed quarterly foreign income estimates/tax provisions; and

• Reviewed/prepared Form 5471s.

Edison Mission Energy-Irvine, California-Senior International Tax Analyst, (April 1993-October 1996)

• Analyzed foreign transactions and their U.S. tax consequences.

• Conducted tax review of project models;

• Interacted with domestic and foreign controllers, treasurers, legal departments, and government officials when foreign transactions were proposed; Richard K. Friedrich Page

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• Evaluated and recommended local tax and accounting firms for pre-operational and post-operational projects;

• Interacted with foreign legal and tax consultants on proposed transactions;

• Reviewed/prepared Form 5471s;

• Created earnings and profits/foreign tax credit database; and

• Determined the yearly Internal Revenue Code Section 861 allocation. Liquid Carbonic Industries-Chicago, Illinois-International Tax Analyst, (December 1989-March 1993)

• Created/maintained earnings and profits, and foreign tax credit database;

• Prepared quarterly subpart F reports;

• Conducted tax research for tax planning purposes; and

• Supervised tax interns.

Square D Corporation-Palatine, Illinois-International Tax Analyst, (November 1988-December 1989)

• Calculated earnings and profits for 100 controlled foreign subsidiaries;

• Determined foreign tax credit; and

• Participated in dividend planning.

John R. Waters & Company-Chicago, Illinois-Staff, (January 1981-November 1988)

• Prepared tax returns for individuals, small C-Corporations, S-Corporations, partnerships, and trusts. EDUCATION

• DePaul University--Chicago, Illinois

Master of Taxation, 1989

• Keller Graduate School Of Management--Chicago, Illinois Master of Business Administration [concentration in accounting/finance], 1986

• University Of Wisconsin--Milwaukee, Wisconsin

Bachelor of Science [concentration in mathematics], 1980 OTHER LANGUAGES SPOKEN

German-Conversational

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