International Tax Planning
Resume:
Guy M. McDonough, Domestic & International Tax Counsel
**********@*****.***
A tax practitioner with more than eighteen years’ experience in domestic (Federal and State) and international income and estate tax and business planning; complex audit management, defense, and negotiations with U.S. and foreign Revenue Authorities as representing individual, entity, and entity based investors, corporate and “hybrid” structures, complex partnerships and LLC’s.
Admitted to the Connecticut State Bar, Juris #412463.
EXPERIENCE
McElroy Deutsch Mulvaney & Carpenter, LLP, Hartford, CT. 2008-2013.
Of Counsel, Federal and International taxation.
Provided U.S., international, and worldwide tax planning and advisory services to businesses as existing or proposed under domestic and/or foreign law. Services include business entity formation, for profit, non-profit, ownership, management, investment objective, and tax transactional efficiency planning as appropriate to achieving the lowest possible world wide "overall tax effective rate" given each client’s available resources, market presence and expansion objectives, and business life cycle in re: the short, medium, or long term capital requirements of each enterprise.
Ogle International Tax Advisors, Bradenton, FL 2006 - 2008
International Tax Director Provided domestic and international tax planning and compliance services to U.S. and foreign corporations, partnerships, and individuals in Asia, The Americas (emphasis in Central America), and Europe. Services included detailed analysis, planning, and compliance under the rules governing the taxation of corporate distributions and adjustments, partners and partnerships, domestic and foreign source income, and the treatment of capital gains and losses. Services also included tax-planning opportunities under the “check the box” entity classification rules. Services generally provided on a tax memorandum basis.
Gartner, Inc., Stamford, CT 2005 – 2006
Tax Consultant, Contract Basis Provided state, local, and federal tax compliance services in connection with Gartner, Inc.’s 2005 acquisition of The Meta Group. Prepared pre-acquisition (amended) and post-acquisition state and local property and sales tax returns and Forms 5471 and 926. Assisted senior management in reconciling The Meta Group’s pre- acquisition reported financials (consolidated, in part) with those as integral to Gartner, Inc. as acquired, and ensuring The Meta Group’s compliance with its reorganization disclosure and entity classification filing obligations under U.S. law. Was specially tasked to provide additional services in connection with Gartner, Inc.’s Canadian tax compliance obligations and prepare a file memorandum re: applicability of Sections 280G & 4999 to certain pre-acquisition payments.
KPMG, LLP, Hartford, CT January 2004 – June, 2005
Senior Associate, Corporate & Pass-Through Tax
Provided tax compliance and strategic planning services to clients in the commercial real estate, financial services, and Alternate Investment (“Hedge Fund”) industries.
ESPN, Inc., Bristol, CT September, 2001 – June, 2004
Senior Assistant to the Chief Tax Counsel
Provided domestic and international tax planning and compliance services to ESPN, Inc., its domestic and foreign entities, and joint ventures in which the company or its parent, The Walt Disney Company, held direct or indirect interests. Supported and advised Chief Tax Counsel on all transactional matters on a world wide basis and in ensuring global compliance with domestic and international transfer pricing rules, to include those of Argentina, Brazil, India, U.K. Switzerland, Luxembourg, and EU Member Nations. Personally responsible for complex audit preparation and defense, negotiation, and successful (cont.) resolution of multiple IRS “Notices of Proposed Adjustment” (“NPA”) as issued pursuant to permanent IRS audit and oversight of The Walt Disney Company, Burbank, CA, to encompass ESPN and two hundred plus domestic and international subsidiaries. Result under my management: proposed adjustments in excess of $145M settled for less than $7M in cash and foregone deductions. Also personally directed local management and counsel in regulatory filings, audit negotiations, and litigation with tax authorities and third parties in Argentina, Brazil, Mauritius and India, U.K., France, Germany, Singapore, and the PRC.
KPMG, LLP, McLean, VA October, 1999 – September, 2001
Senior Associate, International Corporate Tax Services
Provided domestic and international tax planning and compliance services to U.S. and foreign-based companies in Asia, The Americas, and Europe. Services included tax legal entity planning under the entity classification, foreign tax credit, and “controlled foreign corporations” rules.
PricewaterhouseCoopers, LLP, Hartford, CT September, 1998 – 1999
Senior Associate, Tax and Legal Services
Provided Domestic (State and Federal) and international tax compliance and strategic planning services.
Washington Counsel, P.C., Washington, DC 1996 – 1998
Associate, Domestic and International Tax Planning, Legislative Analysis.
Provided Federal and International Tax Strategic Analysis, Advocacy, Legislative monitoring, and guidance to a wide range of clients as representing the Insurance, Banking, Securities, Housing, and Energy Sectors. Actively participated as member of several Washington based tax and trade policy and advocacy Groups, providing recommendations to same as concerning Congressional efforts to reform, simplify, and implement changes to the Federal Income Tax.
PRE-LAW, HIGHLIGHTS
National Republican Congressional Committee, Washington, D.C. 1990 – 1992
Special Assistant to the Chief Counsel, Federal Election Law.
White House Appointee, Bush I Administration, The Pentagon.
Special Advisor to the President, Technology Security.
Advisor, & Liaison, Deputy Secretary, Trade Security Policy 1989 – 1990 •
Campaign to Elect The President: Bush/Quayle ’88, Washington, D.C. 1987-1988
Senior Assistant to the Comptroller, Campaign Finance. Responsible for financial oversight, resource deployment, and compliance with all applicable Federal Election Laws Midwest Region 1987 – 1988
EDUCATION •
Juris Doctor, Univ. of Colorado School of Law. Certification in complex U.S. and international tax 1995.
Bachelor of Arts, Political Science, Univ. of Colorado, Boulder. Emphasis in European, Russian/Soviet History, Government Studies, 19th and 20th Century Russian/Soviet Foreign Policy 1986
Personal and professional references available upon request.
Guy M. McDonough, Federal and International Tax Counsel,
Description of Services:
Provided U.S., international, and worldwide tax planning and advisory services to businesses as existing or proposed under domestic and/or foreign law. Services include business entity formation, for profit, non-profit, ownership, management, investment objective, and tax transactional efficiency planning as appropriate to achieving the lowest possible world wide "overall tax effective rate" given each client’s available resources, market presence and expansion objectives, and business life cycle in re: the short, medium, or long term capital requirements of each enterprise.
A genuine understanding and appreciation of each clients particular situation and perspective having thus been acquired, it then becomes possible to undertake a “best methods” analysis to specifically identify and then implement the optimal methodology for achieving the compensation, equity appreciation, and long term return on capital benchmarks of key ownership and management personnel. Clients who have benefited tremendously from this process include mid- to large size privately held corporations, partnerships, LLC’s, and combinations thereof as formed under U.S. and/or foreign law. Depending on client need and situation, certain additional services as perhaps necessary to achieve the requisite result(s) may also be required, to include start up or mezzanine third party financing, recapitalization finance by straight and/or convertible debt, or audit settlement and litigation management.
As Counsel, bring over eighteen years of domestic and international tax planning experience, acquired in a wide range of environments, to include a tax and trade lobbying and law firm based in Washington, D.C., the international and corporate tax departments of two of the largest accounting firms in the world, and four years as International Tax Counsel to ESPN, a subsidiary of worlds largest entertainment and media company. Services have been provided to clients based and/or doing business in virtually every developed and most developing markets, with a special emphasis on UK, EU, Swiss, other European, Asian, Indian subcontinent, and Central and South American markets.
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