Dan has nearly 15 years of experience advising both U.S. and non-U.S. multinationals, either publicly traded or privately held on a broad range of U.S. and international tax issues, and leading cross-functional client service teams in identifying and implementing solutions for clients.
He has extensive experience in providing international tax advice on a wide range of tax matters including but not limited to mergers and acquisitions, post-acquisition integration, internal restructuring, cross-border financing, foreign tax credit planning, tax-efficient cash repatriation strategies, and intellectual property planning. Dan is also frequently assisting clients with navigating, and planning for, the complexities of U.S. and non-U.S. tax legislative developments.
Dan works closely with the following industries: consumer and industrial products, manufacturing, software and technology, media and entertainment, pharma and life science.
- Advises large publicly traded and privately held outbound multinationals on cross-border matters including acquisitions, divestitures, restructurings, IP migration, cash repatriation, debt simplification, debt pushdown, due diligence and other such matters
- Advise inbound clients on U.S. legal entity structure set-up, U.S. trade or business (USTOB) and effectively connected income (ECI), financing options, debt/equity recast issues, significant debt modification, outbound payments, cash repatriations, treaty eligibility, withholding, Form W-8BEN-E, anti-conduit rules and FIRTPA
- Assists in preparation and review of international tax compliance forms as well as quantitative solutions and supporting documentations
- Advise multinational on merger and acquisition (M&A) transaction step plan design towards maximizing tax attribute utilization to reduce transaction costs
- Advise large multinationals on Pillar 2 related matters including assessing “qualified” status of CBC report, preparing transitional safe-harbor computations, review GloBE computations and transaction design
- Advised on mitigating indirect transfer tax consequences in more than 30 jurisdictions in connection with a $3.5 billion acquisition
- Serves as a main point of contact and project lead for clients in identifying and implementing strategic holistic solutions for U.S. and foreign direct and indirect tax issues arising from day-to-day business operations and financial transactions worldwide
- American Institute of Certified Public Accountants, member