• Section 382 study for San Francisco software company with $40MM in revenue and large NOLs; analysis of C and D rounds of venture financing; identification of assets with unrealized built in gains and planning for future utilization.

• Assistance in two separate situations to software companies deciding whether to make asset purchases or C reorganizations; weighing asset step up versus NOL carryovers; draft documents in one case where decision made to go forward with C reorganization

• Costing studies and opinion on the use of the Extraterritorial Income Exclusion regarding export sales under section 114 of the Internal Revenue Code.

• Opinion letter to San Francisco newspaper on accounting for advance payment of subsidies

• Research and structuring project on state tax nexus and sales factor requirements for seller of wind turbines. Focus on Oregon, Washington and North Dakota

• Assistance on and drafting of management services agreement to be used in state tax planning

• Draft correspondence for separate employee groups on FICA refund opportunity and preparation and filing a claim for refund of employer portion of tax

• Cost push down analysis and documentation for state income tax planning project for large US manufacturer

• Transfer pricing analysis and written study on the provision of credit and services in international context and in state allocation context

• Currently teaching M&A course at Golden Gate University Graduate School of Tax; have taught corporate, consolidated return, partnership and S Corporation tax classes there for 15 years.