Managing Director Education Background
Masters of Science in Tax Law (MST) – Golden Gate University
A comprehensive graduate degree program designed to train professionals in the tax field. Each master’s in tax law course takes approximately four months to complete. These advanced tax courses require a significant amount of time and effort to master as the material is highly complex requiring detailed study and analysis. Many of the tax courses are very similar to the tax law courses taken by attorney’s in their Masters of Tax Law program. This MST program, similar to an LL.M. (Taxation) program, takes three to five years to complete if done as a part-time arrangement, which is commonly the case as most tax professionals are working full time when completing this program.
(20) TA 352 Taxation In Electronic Commerce – Completed in August of 2017, this course provides comprehensive examination of the tax issues confronted by companies engaged in electronic commerce, with special attention to remote sellers. Areas of taxation studied include state sales tax, state income tax, cross-border (international) transactions, tax accounting for web site development costs, acquisitions and dispositions of web-based businesses, valuation issues and tax compliance associated with e-commerce. The course emphasizes six unique aspects of e-commerce taxation, including: worldwide reach of web sites, anonymous transactions, digital products, remote operation of a web server, intangible assets in web sites, and fast-changing rules.
(19) TA 350D Transfer Pricing – Structuring transactions among related parties operating in an international context provides opportunities for tax planning through the shifting of income to lower-taxed jurisdictions. Section 482 of the Code and its regulations are the primary means through which the federal government limits tax avoidance by requiring that the pricing of such transactions for tax purposes reflect the prices that would result if the parties were operating at arm’s length. This course examines the principal aspects of transfer pricing, focusing on relevant statutory, regulatory, treaty, case law, including non-U.S. approaches such as OECD guidance, and considers the historical and conceptual basis of the current system. Economic and tax accounting aspects of transfer pricing are discussed along with the practical application of different transfer pricing methodologies. The course also considers the administrative aspects of transfer pricing, including IRS examinations, APA procedures, and competent authority procedures. Class material includes: Transfer Pricing: Rules, Compliance and Controversy – (CCH, Latest Edition), Marc M. Levey & Steven C. Wrappe, the latest Treasury Regulations, and various transfer pricing articles.
(18) TA 350A Taxation of Foreign Persons with US Activities – Examines business and investment transactions by nonresident alien individuals and foreign corporations earning income in the US (inbound transaction) including residence for income taxation, sources of income, sources and allocation of deductions, US taxation of passive income by nonresident aliens and foreign corporations, the branch profit tax and gains of foreign taxpayers from the sale of US Real Property.
(17) TA 321 Principles of International Taxation – Presents a broad survey of the rules of US income taxation regarding international transactions. Covers both “in-bound” transactions the treatment of non-resident aliens and foreign corporations investing and/or doing business in the united States, as well as “out-bound” transactions the treatment of US citizens and residents investing and/or doing business outside the US.
(16) TA 350B Taxation of US Persons with Foreign Activities – Covers US taxation of foreign operations by US individuals and corporations including an in-depth analysis of the foreign tax credit, controlled foreign corporations, passive foreign investment companies, foreign sales corporations, and foreign currency transactions.
(15) TA 333 Consolidated Income Tax Returns – Analyzes consolidated tax return law, including concepts and history; eligibility to file: computation of consolidated and separate taxable income; intercompany transactions; SRLY rules; and consolidated basis adjustment procedures.
(14) TA 338 Tax Timing – Examines issues related to the allocation of items of income and deduction to the proper taxable year, including adoption of tax year end; definition of method of accounting; the annual accounting concept; cash, accrual and installment methods of accounting; time value of money; and the Uniform Capitalization Rule.
(13) TA 396B International Tax Planning – Examines structuring of overseas operations, including special tax features in leading jurisdictions, hybrid instruments and entities, anti-avoidance and intellectual property rules, repatriating profits, foreign acquisitions and international holding companies.
(12) TA 322B Federal Income Taxation of Corporations and Shareholders Part 2 – Continues analysis of tax treatment, tax problems and tax planning techniques involving transactions between corporations and their shareholders. Covers specific issues of operating in corporate form: corporate organizations and divisions, carryovers of tax attributes. and limitations on carryovers.
(11) TA 326 Real Estate Taxation – Analyzes tax advantages of ownership of real property; how to acquire real property; choice of entity; ownership and operation of real property; sales, exchanges, conversions and abandonment; postponing taxation on sale; tax aspects of mortgage financing; foreclosures and cancellations; leasing real property; hybrid financing through sales and lease backs; partnerships. subdivisions, syndicates, real estate investment trusts; ownership by homeowners associations, co-ops, tax exempt and foreign investors and real estate holding companies.
(10) TA 328 Federal Income Taxation of Partners and Partnerships – Analyzes tax problems of the organization and operation of partnerships including the treatment of partnership distributions, withdrawal of a partner during his/her lifetime, dissolution of the partnership, sales or exchanges of partnership interests.
(9) TA 322A Federal Income Taxation of Corporations and Shareholders Part 1 – Analyzes tax treatment, tax problems and tax planning techniques involving transactions between corporations and their shareholders: transfers to corporation; capital structure; dividends and other distributions; stock redemptions and liquidations; stock dividends and preferred stock bailouts; and introduction to S corporations.
(8) TA 330 Property Transactions – Analyzes federal income taxation of property transactions, including definition and mechanics of property transactions, definition of capital assets, nonrecognition property transactions, including I.R.C. Sections 121, 1031 and 1033; examination of the “at risk” and “passive loss” rules. TA 338 Tax Timing – Examines issues related to the allocation of items of income and deduction to the proper taxable year, including adoption of tax year end; definition of method of accounting; the annual accounting concept; cash, accrual and installment methods of accounting; time value of money; and the Uniform Capitalization Rules.
(7) TA 319 Federal Tax Procedure – Procedural aspects of dealings between taxpayers and their representatives on the one hand and the Internal Revenue Service, IRS Office of Professional Responsibility, the Office of the Chief Counsel for the Internal Revenue Service, and the Tax Division of the Department of Justice on the other hand.
(6) TA 320 Multistate Corporate Taxation – Analyses the tax treatment, tax problems and tax planning techniques of corporations engaged in multistate activities. Emphasis is on California law with substantive discussion of other state laws. Topics include Constitutional limitations on states ability to tax multistate corporations, general vs, financial corporations, state treatment of S corporations, FCSs, holding companies and partnerships, computation of income, business versus non business, formula apportionment, unitary taxation and water’s edge elections. Court case studies are used to illustrate concepts.
(5) TA 346M Passive Loss Activity Rules – Examines the complex and ever-changing passive activity loss (PAL) rules that apply to certain investments in trade/businesses and rental properties with an in-depth coverage of tax law and regulations applicable to passive activities. Objectives include gaining a thorough understanding of the passive activity loss rules, understanding how to optimize tax benefits with respect to PALs, learning how to identify what activities are subject to the PAL rules and applicable special exceptions and understanding the tax ramifications of losses and dispositions of PALs.
(4) TA 318 Advanced Federal Income Tax Law – Examines federal income taxation with emphasis on statutory materials; special attention to problems of individual taxpayers and specific rules regarding gross income, adjusted gross income, taxable income, deductions, exemptions and credits.
(3) TA 329 Tax Research and Decision Making – Examines the primary sources of income tax law, the IRC, and administrative and judicial interpretations. Teaches skills required to locate, understand and interpret primary source law materials.
(2) ACCTG 301B (Equivalent) “Principles of Accounting” – Provides insight into current, relevant accounting topics, and the underlying accounting standards (FASB Codification). Topics include long-term debt, complex debt/equity instruments, stockholders’ equity, share-based payments, leasing, income taxes, consolidation (VIEs), income taxes, and partnerships/joint venture accounting. Imparts an understanding of the practical issues in the appropriate accounting for transactions that are covered under these topics.
(1) TA 362 (Equivalent) “Accounting for Income Taxes” – Examines the financial accounting and reporting of income taxes under Statement of Financial Accounting Standards Codification Topic 740 (FASB ASC 740) formerly known as FAS 109 and related accounting literature. Topics include the calculation of current and deferred income taxes, an overview of book-tax differences, the calculation of interim period tax provisions and the presentation and disclosure of income taxes in financial statements. Students will learn the basics of accounting for income taxes related to advanced topics such as stock compensation expense, foreign operations, state income taxes and accounting for uncertain tax positions (formerly known as FIN 48). The difference between US and international accounting standards will be identified and discussed.
Graduate Certificate Degree in International Tax Law – Golden Gate University
In-addition to completing a Masters in Taxation I have also just recently (August of 2017) completed all of the courses required to obtain my graduate certificate degree in international taxation.
Bachelor of Economics, Accounting – University of California, Santa Barbara