PwC US has announced that Mark Carlson from its Cincinnati office has been admitted into the firm’s partnership. He sits within the International Tax Services practice.
Carlson brings more than 16 years of professional experience, including a two-year assignment with PwC Luxembourg, and specializes in advising U.S. and foreign multinational companies in cross border restructuring transactions, local country tax optimization, accounting for income taxes, foreign tax credit planning, tax compliance and quantitative analysis. Carlson also currently serves as part of PwC’s Integrated Global Structuring Team. He received his bachelor’s degree in accounting from the University of Saint Francis and is a Certified Public Accountant (CPA), licensed in Minnesota and Ohio.
The International Chamber of Commerce (ICC) has announced the appointment of Paul Morton as the new Vice-Chair of the ICC Commission on Taxation. Mr Morton will take over from Mr Chris Lenon, who stepped down from the position on 30 June 2014.
Since 2005, Mr Morton has been the Head of Group Tax at Reed Elsevier, where he leads a team of tax professionals based in London, Oxford, Amsterdam, Boston and Singapore, serving businesses operating in more than 90 countries.
Before joining Reed Elsevier, Mr Morton led the tax team for Royal Dutch Shell’s global marketing and refining division. Prior to this, he was a tax manager at KMPG and a tax inspector in the UK’s Inland Revenue. Mr Morton is Chairman of the British Branch of the International Fiscal Association and a member of the Business and Industry Advisory Committee (BIAC) to the Organisation of Economic Cooperation and Development (OECD). He is actively engaged in OECD Base Erosion and Profit Shifting (BEPS) consultations and frequently takes an active role in various tax-conferences, including recent G8 and G20 meetings.
Mr Morton said: “The international tax system is in a period of change as great as that over 80 years ago when the foundations of the modern system were laid down. It is vitally important that the business community engages with policymakers as they grapple with the enormous challenges of adapting the accepted international tax principles to 21st century business models. ICC is perfectly placed to draw on the deep insights of businesses around the globe and I look forward to contributing to the on-going dialogue. Tax has become a matter of wide public concern and it is essential that the business community plays its part in providing perspective and in engaging with a much broader spectrum of stakeholders than in the past.”
Mr Morton will take over the reins from Chris Lenon. Mr Lenon has contributed greatly to the work of the Commission on BEPS and the Commission’s cooperation with the BIAC to the OECD. Furthermore, Mr Lenon represented ICC at the EU Platform on Tax Governance and played a key role in putting forward ICC’s views on environmental taxation principles. ICC extends its great appreciation for the expertise and contribution that Mr Lenon provided.
The ICC Commission on Taxation analyses developments in international fiscal policy and legislation and puts forward business views on government and intergovernmental projects affecting taxation. It currently comprises approximately 150 international tax experts from all sectors of business and private practice, including representatives from some of the world’s leading companies and tax consultancy firms. In order to engage business views and tackle issues related to international taxation, the Commission on Taxation works closely with organizations such as the UN Committee of Experts in Tax Matters, the OECD, BIAC and the International Fiscal Association.
KPMG is recruiting up to 30 corporate tax compliance professionals in its Birmingham office, to establish a satellite Tax Centre of Excellence for corporate tax compliance.
Janette Wilkinson, head of corporate tax at KPMG in the UK, said: “Tax compliance is the important job of helping clients – either individuals or companies – make sure their tax returns are in order. This means they are in full compliance with applicable tax regulations and that the necessary information has been given to the tax authorities along with the required supporting evidence.
“Across our 22 UK offices we currently prepare and submit around 8,500 corporate tax returns to HMRC every year. Establishing this satellite corporate Tax Centre of Excellence in Birmingham to complement our existing Tax Centre of Excellence in Glasgow is a major step in our consolidation of this important compliance work to central hubs. The Birmingham team will work closely alongside their colleagues in Scotland, building on the work that the team in the Glasgow centre has achieved to date.
The new hub will be located in KPMG’s existing Birmingham office at One Snow Hill and is due to open in September this year.
The roles on offer are full time or part time and offer flexible working arrangements. To find out more and/or apply, please click here: http://www.etaxjobs.com/candidate/recruiter-jobs-kpmg-birmingham-corporate-tax-jobs-936.html
Hern Kuan has joined Rajah Tann as a tax partner in the Singapore office.
Hern Kuan was introduced to tax law in 1991. He was, prior to joining Rajah & Tann LLP in 2014, the Chief Legal Officer of the Inland Revenue Authority of Singapore (IRAS) for 10 years. Prior to his 14 year stint in IRAS, he was a tax manager with KPMG and PwC, and a lecturer with the Faculty of Law, National University of Singapore.
While at IRAS, he was, with his colleagues, involved in providing all manner of legal and tax advice to IRAS’ operational divisions, tax law interpretation, tax rulings, international matters, enforcement proceedings, audit, investigation and criminal prosecution matters, and drafting of tax legislation. He has also represented IRAS as lead counsel in civil and criminal court proceedings in the various boards of review and the Supreme Court.
Notable Cases & Transactions
AQQ v CIT  SGCA 15,  SGHC 249,  SGITBR 1
AQP v CIT  SGCA 3
BQM v CIT (2011) MSTC 50-004 (SGITBR)
Clifford Development v Commissioner of Stamp Duties  SGCA 17,  SGHC 168
City Developments Limited v Chief Assessor  SGCA 29,  SGHC 227, (2007) MSTC 5,598 (SGVRB)
UOL Development (Novena) Pte Ltd v Commissioner of Stamp Duties  SGHC 173
First DCS Pte Ltd v Chief Assessor  SGHC 82
IE v CIT (2007) MSTC 5,656 (SGITBR)
Comptroller of Income Tax v IA  SGCA 24,  SGHC 229, (2005) MSTC 5,456 (SGITBR)
Comptroller of Income Tax v HY  SGCA 7,  SGHC 137, (2005) MSTC 5,439 (SGITBR)
T Ltd v Comptroller of Income Tax  SGCA 13,  SGHC 115
JD v Comptroller of Income Tax  SGCA 52,  SGHC 92, (2005) MSTC 5,391 (SGITBR)
HZB v CIT (2005) MSTC 5,508 (SGITBR)
UDPL v CIT (2005) MSTC 5,331 (SGITBR)
Kuok (Singapore) Ltd v Commissioner of Stamp Duties  SGHC 81
BCH Retail Investment Pte Ltd v Chief Assessor (2003) MSTC 7,439 (SGHC)
MMR v CIT (2001) MSTC 5,305 (SGITBR)
Memberships / Directorships
Member, Law Society of Singapore
Member, Singapore Academy of Law
Devereux Chambers has further expanded its team of tax specialists with the arrival of Felicity Cullen QC, formerly of Gray’s Inn Tax Chambers.
She arrives with a balanced practice of contentious and advisory work which spans the full range of commercial tax, property tax and private client work. In recent years she has appeared in many important tax cases including RKW Limited v Commissioners for Her Majesty’s Revenue & Customs.
Speaking about Felicity Cullen’s arrival, Timothy Brennan QC, Head of Chambers said ”We are delighted that another distinguished tax practitioner has chosen to join us. Felicity adds yet more strength and depth to our tax specialism. “
Felicity deals with all aspects of revenue law though she is primarily involved in commercial tax, both in an advisory and litigation context. On the advisory side, she has been involved in many large city transactions and is routinely involved in private company and business transactions, such as the recent substantial investment into Greenwich Peninsula by Hong Kong investors.
The disputes side of her practice entails correspondence, settlement negotiations, and other forms of dispute resolution such as mediation, as well as appearances in tribunals and courts. For example, she recently settled a permanent establishment dispute against HMRC involving profits of circa £150 million. She has appeared in many leading tax cases in the courts in recent years and has acted for parties in tax related mediations. She also deals with personal taxation, including capital taxation, again in the giving of advice and assisting with the resolution of disputes.
Other Notable cases include:
RKW Limited v Commissioners for Her Majesty’s Revenue & Customs – First-tier Tribunal (Tax) – 30 January 2014
Her Majesty’s Revenue and Customs v. Salaried Persons Postal Loans Limited – Chancery Division – 7 April 2006
Salaried Persons Postal Loans Limited v. Commissioners of Revenue and Customs – Special Commissioners – 5 October 2005
John C McBride v. Stephen John Blackburn (HM Inspector of Taxes) – Special Commissioners – 23-25 September 2002
Trustees of British Telecom Pension Scheme & others v. Clark (HMIT) – Court of Appeal – 24 February 2000
A Pardoe (HMIT) v Entergy Power Development Corporation – Chancery Division – 23 February 2000
Clark v. Trustees of British Telecom Pension Scheme & others – Chancery Division – 14 October 1998
Trustees of British Telecom Pension Scheme & others v. Clarke – Special Commissioners – 16 December 1997
Bricom Holdings Limited v I.R.C. – Court of Appeal – 25 July 1997
Vodafone Cellular Ltd v. Shaw (Inspector of Taxes) – Court of Appeal –  STC 734
WilmerHale has welcomed Matthew Schnall as a partner in the Boston office and a member of the Tax Practice Group.
Mr. Schnall represents clients in tax controversies, transactional planning, administrative ruling requests, and tax regulatory compliance. Mr. Schnall boasts substantial experience advising clients on the tax aspects of mergers and acquisitions, spin-offs and split-offs, equity and debt financings, registered and private investment funds, business liquidations, restructurings and workouts, as well as international and partnership tax issues. He has handled tax controversies before a variety of state and federal tribunals and joins WilmerHale from the Boston office of a major law firm.
“WilmerHale is a highly successful and widely-respected firm, I look forward to joining them.” noted Mr. Schnall. “I have worked with and across from WilmerHale’s tax lawyers in a number of contexts over many years. I have the utmost respect for them, and am excited to work as part of their team.”
Since 2004, Mr. Schnall has been recognized by Chambers USA as a leading tax lawyer in Massachusetts. He is also consistently ranked as a top tax lawyer by The Best Lawyers in America and among the list of Massachusetts Super Lawyers.
Mr. Schnall is an adjunct professor in the Boston University Law School Graduate Tax Program and speaks frequently on topics in federal, state and international taxation. He earned his JD from Harvard Law School and his AB from Harvard College.
Sandra Van De Walle has joined WTAS Houston as a Director in the firm’s National Tax Office. Sandra is the third addition to the WTAS National Tax Office in the past year, and adds National Tax Office presence to the newly established Houston office.
Sandra has over 23 years of experience in tax and has knowledge in strategic development and the launch of new businesses in domestic and international markets. She is well versed in working with the corporations to ensure they meet the requirements of federal, state, and international tax laws.
Prior to joining WTAS, Sandra served as the Tax Director at Carbo Ceramics. She most recently worked with UHY Advisors in Houston as their National Tax Operations Director.
“Sandra is a tremendous addition to our National Tax team. She has a terrific combination of deep technical expertise and broad experience,” said Ellen MacNeil, leader of the WTAS National Tax Office.
Chris Bowers has left Bingham McCutchen to join Skadden Arps.
He advises clients on all aspects of international tax planning and controversy, representing many of the largest U.S. and international financial institutions, as well as large, multinational companies. He focuses on issues arising in cross-border financings, cross-border mergers and acquisitions, and foreign tax credit planning.
Before joining Skadden in 2014, he was a partner at Bingham McCutchen. Prior to that, he was a partner in the International Corporate Services Group at KPMG LLP’s Washington National Tax Office. Earlier in his career, Mr. Bowers clerked for Supreme Court Chief Justice William H. Rehnquist and the Hon. Pamela Ann Rymer of the U.S. Court of Appeals for the Ninth Circuit.
Mr. Bowers is listed as one of the country’s leading tax practitioners in Chambers USA: America’s Leading Lawyers for Business. He also has been included in The Best Lawyers in America, The Legal 500 U.S. and International Who’s Who of Corporate Tax Lawyers.
Mr. Bowers has co-authored numerous articles on a wide range of international topics that have been published in leading tax journals, including Tax Management International Journal, Tax Notes and Tax Notes International. He also is an adjunct professor at Georgetown University Law Center, where he teaches international taxation, and served as an adjunct professor of law for corporate taxation at the George Mason University School of Law in 2004.