Senior таргетолог · gambling, betting

Sign in regulatory & compliance/tax Accounting, Pub.Admin, Grad.Law (J.D.) Location: Bellevue, NE Salary: Negotiable w. reasonable accommodations Posted: November 01, 2018 Contact this candidate Resume: Christopher e Schlegel, senior partner Practice & Teaching C&I Curriculum Vitae schlegel & maisonave www.linkedin.com/in/christopher-schlegel-452b9b3 schlegel direct dial: 402-***-****' Email: **********************@*****.*** Firm principal: ********************@*****.*** Metro Omaha Direct Line: 402-***-**** eeoc notice: reasonable accomodation ADA "major life activity" physical disability Expertise [tax accounting] [tax law] [business law] [administrative law] [disclosure & federal crimes] Regulatory & compliance: Federal and state regulatory undertakings, administrative law practice, due diligence matters, business legal affairs. White collar financial crimes: (1) Bank fraud, (2) Investment schemes, (3) Money laundering, (4) Racketeering, (5) Securities fraud, (6) Tax fraud, conspiracy, aiding/abetting and evasion. Advanced Tax Matters: Domestic, international and cross-border tax planning, tax compliance and administration, state and local taxes, and tax controversy defense practice. The structure of complex business arrangements such as the acquisition and disposition of assets, stock and interests in corporations, partnerships and joint ventures, business securities. Formation of profit and non-profit business entities, tax exempt entity matters; the purchases and sales of businesses and real estate; business succession planning; tax planning; tax audits; administrative appeals briefing of contested issues; tax litigation, trial pleadings (motions, briefings, evidence schedules). Thomson Reuters onesource™ corporate tax software, RelativityOne ediscovery investigative software. Tax Audit Data Analytics: Descriptive analytics, Diagnostic analytics, Predictive analytics, Prescriptive analytics. Predict future outcomes using regression-based modeling. Education Juris Doctor, University of Oklahoma College of Law (1983) Advanced Federal Taxation 19 Hrs: 3.68/4.00 GPA Business & Public Administration Graduate curriculum, 24 Hours: 3.75/4.00 GPA Bachelor of Science, Public Accounting, Penn State University Smeal College of Business Administration (1980) Core Curriculum 30 Hrs: 3.40/4.00 GPA; Bachelor of Science, Public Policy Studies, Penn State University School of Public Affairs (1980). Advanced curriculum, 55 Hours: 3.79/4.00 GPA Total Credit Hours Earned: 269 Varsity Letter, Penn State Intercollegiate Debate and Public Speaking [2] Professional Practice, Federal Government & Academia Academia: Institute for Policy Research and Evaluation (IPRE), Penn State University (1978-1980) Data analysis, Applied research methods, public program analysis, quantitative policy analysis on federal research grants. Major emphasis in urban economic theory, government budgeting administration, state & local government personnel management; Public management information systems and policy implementation strategies. Law Clerk to AICPA-member firms (1981-1983), 2nd Year Law, 3rd Year Law. Read into firm protocols for engagement, work product confidentialities. Federal Government: U.S. Treasury, IRS Southwest Regional Counsel. Law Clerk to major case appeals. U.S. Courthouse, 200 N.W. 4th Street, Oklahoma City, Oklahoma. (1983-1984) Representative contested cases: Halliburton Companies, U.S. taxation of international business operations; Beech Aircraft Domestic International Sales Corporation (DISC) subsidiary; Carnation Foods offshore subsidiaries. Carnation v. Commissioner, 71 T.C. 400 (1978), affd. 640 F.2d 1010 (9th Cir. 1981) cert. denied 454 U.S. 965 (1981); Phillips Petroleum international oil & gas exploration; Oklahoma Gas & Electric energy contracts. Research and assessment of complicated federal tax issues involving international entity formation, chain structuring for tax avoidance purposes, closely-held corporations (CHCs), M&As. Conducted reviews of IRS regional tax audits, appeals, proposed settlements, trial pleadings, and the draft of pretrial appellate opinions on major case tax controversies ("unreasonable understatement of tax liability," IRC §6694, 26 U.S.C. 6694). Managing Partner, Schlegel Rice & Massey (1984-1993). Boutique. Expertise: Oil & Gas Taxation. Tax Counsel, USPCI Inc.-Union Pacific. Tax Counsel, New England Life Insurance Oklahoma City. Oklahoma City and Philadelphia. Practice limited to: Advanced Tax Matters Practice. U.S. Taxation of International Transactions. Consent opinions. Managed federal & state tax filings: Corporations, partnerships, trusts and estates, complex individual tax controversies. Exempt organizations practice. Managed and prepared applications for determination letters. SFAS interpretation, SOX compliance in supervision of financial statement audits and preparation of internal corporate reports. Instrumental in coordination of federal, state & local intergovernmental regulatory scheme integration and compliance strategies and tactics; Conducted due diligence matters and investigations. Drafted U.S. tax opinions and technical memoranda in design of tax-efficient business strategies, restructurings and distribution structures. Managed and participated in a variety of tax matters including: (1) Long Term Tax Planning: conducting research and drafting tax planning strategies; review, propose and draft tax language in contracts; propose business structures for new projects based on U.S. and foreign tax laws, Foreign Account Tax Compliance Act (FATCA); (2) Provided tax analysis for proposed mergers, acquisitions, reorganizations: perform due diligence, structure transactions and review transaction agreements; (3) Provided analysis of U.S. and international tax advantages/consequences of transactions; Compliance filings Forms 5471, 8858, 8865, 1118; (3) Manage contested cases with federal and state revenue authorities: Reply to proposed tax deficiency determinations, draft protests and research taxpayer positions. FASB pronouncements practice; AICPA auditing standards, tax shelter litigation, real estate tax planning, private real estate syndications, advanced partnership taxation, taxation of corporate mergers, recapitalizations and liquidations; Business organization planning. Estate planning, trust and other wealth transfer vehicles for high net worth client base in Texas, Oklahoma, Kansas, Louisiana, California specializing in federal oil & gas taxation, mineral extraction taxation issues, farming and ranching taxation. Represented sole Oklahoma Horse Racing Commission (OHRC) licensee finalist in competition with Edward J. Debartolo Sr. seeking award of Thoroughbred racing, casino and gaming license. Debartolo Sr., owner of Louisiana Downs, San Francisco 49ers National Football League Club and Pittsburgh Penguins National Hockey League Club at the time, proposed a $600,000,000 investment in Remington Park. His investment group was awarded the OHRC license after an administrative hearing. Drafted and approved Thoroughbred breeding and racing investment statutory "pass-through" vehicles in conformity with Treasury circular 230 tax shelter opinions for high-end wealth clients. Advanced Tax Matters Practice:Tax Reorganizations (Acquisitive), §368, and Corporation Separations, §355, 26 U.S.C., Internal Revenue Code of 1986 ("Code"); Transfers of Stock or Assets: Contribution of all operating assets and related liabilities of division to newly formed subsidiary [§368(a)(1)(D)] and subsequent distribution [§355(a)(1)] of its stock to holding company parent. Holding company contributes acquired subsidiary stock to second new subsidiary and distributes stock in second new subsidiary to its shareholders. Reverse Triangular Mergers, Code §368(a)(2)(E); Code §482 Reallocation Theories; Acquisition of Target §382 NOL Corporations; Tax planning implications of CHC "Brother-Sister" and "Parent-Subsidiary" Code §1563 Controlled Groups. Code §§381-382 NOL Tax Attribute Carryovers in qualifying transactions under Code §§368(a)(1)[A], [B],[C],[F],[G] Reorganizations. Code §368(a)(1) [G] Debtor Corporation Reorganizations. Subchapter "K" Partnership Share Allocation Theories, §704; Taxation, §§701-709. Taxation of Partnership Contributions, Distributions, and Transfers, §§721-743. Subchapter "J" Taxation of Trusts, Estates & Beneficiaries: Code §§641-679; Pooled Income Funds. Code §856 REIT Regs. Code §860A REMIC Regs. Multistate Estate Tax Planning, Code §§2001-2057. Estate "Freeze" RECAP Transactions [Ch.14 (§§2701-2704) RRA 1990]; §2701 Corporation "Applicable Retained Interest" RECAP; §2702 Qualified Trust Interests. TRA 1986 GSTT "constructive addition" Triggers: (1) taxable termination, (2) taxable distribution, (3) "skip" person definitions; Code §2613(a)(2)(A). Code §2612(a)(1), (2). Subchapter "F" Code §501(a) EXEMPT ORGANIZATIONS TAX MATTERS: Nonprofit corporation tax law, §501(c) (3). Legal Organizing Documentation, Preparation of Determination Letter Request. Code §509(a)(3) Supporting Organizations; Private Operating Foundations; §503(b) "Prohibited Transactions". Subchapter "D" §401(a) QUALIFIED COMPENSATION TAXATION: Qualification, Coverage, Vesting, Contributions, Benefits; §404 Deductibility; §409 Qualified ESOP "Anti-Takeover" Devices. Non-qualified Deferred Compensation Arrangements [Stock Appreciation Plans, Restricted Property Compensation]. FEDERAL BANKRUPTCY CODE: Title 11 U.S.C. Special Tax Provisions, §346. Allocation of Debtor Title 11 U.S.C. §541 Business Bankruptcy Estate Post-Petition Tax Characteristics. Federal Criminal Tax False Statement Offenses and Criminal Tax Procedure: §§7201-7207. FOREIGN-OWNED REPORTING CORPORATIONS: §6038 [A],[C] [RRA 1990] Record Compilation by Foreign Related Parties: Transaction Records, U.S. Import-Export Transfers ["U.S.-connected products or services"] Intercompany pricing documents, Related foreign transactions, Worldwide Ownership/Capital Structure, Intercompany uncompensated services (Bank Guarantees). SEC Compliance: SEC 1934 Act, 15 U.S.C. §78j(b); Rule 10b-5, 17 CFR §240.10b-5; Securities Transactions constituting 18 U.S.C. §1961(1)(D) Predicate Acts. "In connection with" primary liability theories and "substantial assistance" secondary liability/ aiding and abetting theories. SEC 1933 Act Registration Law. Regulation D Issuer and Transactional Exemptions. State Securities Registration Laws. Federal Criminal Law: RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT ("RICO"). 18 U.S.C. §§1961-1968. Determination of "Enterprise" and "Pattern of Racketeering Activity". §1961(5) Predicate Acts having "the same or similar purposes, results, participants, victims, or methods of commission, or otherwise are interrelated by distinguishing characteristics and not isolated events." Predicate Act Expertise: Mail Fraud [§1341], Wire Fraud [§1343], Laundering of Monetary Instruments [§1956(a)(1) (A)], Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity [§1957(a)]. Federal Bank Fraud [18 U.S.C. §1344]. Misapplication Banking Schemes; False Statements to Financial Institutions [18 U.S.C. §1014]. Interstate transfer and deposit of identified §1344 funds constituting "specified unlawful activity" as defined at 18 U.S.C. §1956(c) (7)[D]. Investigation of pattern of commercial banking transactions encompassing an interstate "float" conspiracy to obtain loans from federally insured banking institutions under false pretenses. §1961(1)(D) "stock park" artifice or scheme to defraud under §10(b) SEC 1934 Act, 15 U.S.C. §78j(b). §1961(1)(D) Chapter 11 Federal Bankruptcy Fraud: 18 U.S.C. §152 "Concealment of Assets" constituting a pattern of racketeering activity; Analysis of Collateral Actor Theories: Violations of §1962(c) conducting and participating in the affairs of the enterprise, Secondary Actor Aiding and Abetting Theory, Conspiracy to violate theory [18 U.S.C. §1962(d)]. Successor Private Practice: Managing Director, Advisory Communications & Public Affairs (1994-2016) Boutique firm. Kansas City, Philadelphia, Tulsa, Oklahoma City. Federal & Multistate Tax Matters, Administrative Law and Regulatory practice, State & Local Government, Exempt Organizations (EO), Small Business lobbying & legislation. (2011) U.S. Oil Field Services LLC Joint Development and Commercialization Joint Venture, Kerfoot Technologies Inc., BISCO Environmental Systems Inc. and Ground Water Treatment & Technology. Corporate counsel advise and consent responsibilities: Opinions, Issue Papers; Advanced tax matters practice and 1934 SEC Act and state securities law regulatory compliance schema. Subpart F, as amended, Tax Cuts and Jobs Act of 2017, international tax planning for controlled foreign companies reconciling foreign currency transactions, I.R.C. §988, 26 U.S.C. §988. White collar criminal matters. Federal statutory and predicate crimes: Mail fraud, wire fraud, bank fraud, securities fraud, insurance fraud, tax evasion and civil fraud. Civil RICO prosecution. 18 U.S.C. §1961 et seq. Government Affairs Practice: Registered Government Lobbyist (2006-2011). Monitor, implement, and assist in influencing federal legislation and treasury regulations. Support review of filing of positions of corporate and partnership tax returns. Coordinated and managed outside attorneys and accountants; Provided client issue advocacy before executive and legislative branches of government; enhanced contacts and relationships; Communicated federal and state regulatory policies; provided regulatory policy advocacy strategies and agenda; instrumental in policy research and analysis to senior management. ABA Subcommittee on Income Tax, State and Local Governments. Recruited, Vice President & Assistant General Counsel, ScotiaMcleod (USA), Investment banking subsidiary of Bank of Nova Scotia. New York, New York. (1991). Member firm, NYSE. Recruited, Chief of Fiscal & Policy Analysis, Delaware Office of the Budget (1986). Interviewed, Assistant Commissioner Tax Policy, Commonwealth of Virginia Department of Taxation (1992). Interviewed (2), Director of Accounting & Finance, Nebraska Department of Labor (2012). FEDERAL TAX LAW CURRICULUM: 19 HOURS, 3.68 GPA[1] ACCTG 206 [A] TAXATION OF CORPORATIONS & PARTNERSHIPS ACCTG 406 [B] TAXATION OF ESTATES, GIFTS & TRUSTS ACCTG 514 [B] ADVANCED CORPORATION TAX THEORY ACCTG 5970 [A] ADVANCED OIL & GAS TAXATION LAW 6110 [A] BUSINESS TAX PLANNING & PRACTICE LAW 6142 [A] ESTATE PLANNING & PRACTICE LAW 5770 [A] INTERNATIONAL TAXATION OF BUSINESS TRANSACTIONS [1]Studied mineral extraction taxation under John P. Klingstedt, PhD-CPA, University of Oklahoma Graduate School of Business, Oil & Gas law under Professor Richard W. Hemingway, University of Oklahoma College of Law. Academia: Faculty (2007-2009) Teaching Curriculum[1] & Instruction (C&I): Accounting case studies, AICPA financial statement presentation, "Present fairly" standard, disclosures, civil and criminal fraud; Federal Tax Law for Business Entities: Partnerships, Corporations, Trusts, Estates; Tax issues research, Auditing, Business Law; Federal and State Employment Discrimination Law; Americans with Disabilities Act, ADA Amendments Act of 2008 [42 U.S.C. §12101 et seq.]. Forensic psychology and DSM-V Axis I,II diagnoses. Health Care Profession Law & Ethics. Wright College, Overland Park, Kansas. Chief Compliance & Regulatory Affairs Officer. ComTech Data Management Corporation (2002-2007) Corporate General Partner; R&D affiliate, LifeLink Data Communications LP (2002-2007) Development stage IPO entities. senior partner, Schlegel & Maisonave (2016-2018): Spinoff subsidiary [ Qsub] for capital gain assets from liquidation of parent triggered by physical disability of managing partner, IRC Sec. 1362(d)(2)(A). Consulting: Agriculture and Energy. Recruited as senior partner, transactional taxation, GABLEGOTWALS, Tulsa, Oklahoma. Federal Tax Position Papers [2018]: Acceleration of Repatriation of Foreign Source Investment by Relaxing Small Business Corporation Shareholder Eligibility Definitions to include non-U.S. Persons and Foreign Corporations at IRC §1361(b)(1)(C) and (D), Tax Cuts and Jobs Act of 2017, as amended, (2018). Do the writings of Gorsuch and Kavanaugh revisiting the abdication of judicial scrutiny under the Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984) "two-step test" and Auer v. Robbins, 519 U.S. 452 (1997) deference to agency rulings or interpretations of their own rules provide an opportunity to argue on appeal contested issues that may now not be considered "unreasonable," IRS Circular 230 §10.34(a)(ii)(B), when subjected to judicial review on such controversial tax positions as CHC parent-subsidiary transfer pricing, IRC §482, and limited partnership partners' distributive share, IRC §704? What would be the effect of the proposed Regulatory Accountability Act of 2017, S. Rept. 115-208 (2018)? treasury circular 230 (Title 31 Code of Federal Regulations) credentials: Commonwealth of Pennsylvania, admission by examination July 26, 27, 28 (1983); State of Oklahoma, admission by examination July 26, 27, 28 (1983). Authority to practice law, §10.3(a). Teaching Portfolio Development of curriculum integrating Federal & State Court Opinions with academic text in lecture lesson plans. Accounting: Construction of Financial Statements; Reviewing an accounting cycle of financial transactions compiled to construct and present financial statements in conformity with U.S. GAAP and FASB. Overview of selected Accounting Regulatory Standards of Practice; Misfeasance, Malfeasance. Federal Tax Law and Compliance Filing for Business Entities1, e.g., C corporations, "S" election corporations, general partnerships, limited partnerships, multistate statutory limited liability companies (LLC). Federal Tax Law and Compliance Filing for Trusts & Estates. Federal Taxation of Natural Resources Extraction (Oil & Gas, Coal and Mineral Ore Deposits). Federal Tax Law Research & Planning2 Business Contracts and Uniform Commercial Code (UCC). Business Equity & Debt Financing, Equity Securities Federal & Multistate Regulation Regimen. International Business Transactions and Select Taxation Architecture Government & Political Science: The Legislative Process. Executive Power and Federal Administrative Agencies. The Judiciary: The U.S. Constitution and Statutory Interpretation. The U.S. Constitution, Statutory Regulation of Commercial Transactions and Religious Liberty. The Divination of Substantive Due Process as defined by Obergefell v. Hodges, 135 S.Ct. 2584 (2015). The Construction of the U.S. Constitution Ninth Amendment's Right to Privacy and its Piecemeal Dismantling under the Rubric of Reinstating Federalism within the Confines of the Tenth Amendment. Public Administration: Liberty Deprivation "under color of law," 42 U.S.C. §1983. Personnel Management: Evidence and Actionable Discrimination. Analytical Techniques for Measuring Public Program Performance. Identifying and Redressing Employment Discrimination Fact Patterns by Pleading Violations of Multistate Constitutional and Statutory Authority; Appeal of Adverse Determinations. Teaching Philosophy The integration of federal and state court opinions into lesson plans in order to illustrate problem-solving techniques confronting career practitioners provides classroom learning experiences, otherwise stale and lifeless, to be demonstratively memorable. Class participation and enthusiasm is significantly increased when opinions are dissected and a lively discussion ensues. This approach also improves the quality of student responses to essay questions and exhibits a better understanding of the subject matter. curriculum & instruction public administration-publicpolicy analysis advanced curriculum, 55 hours: 3.79 GPA Transportation Public Policy & Economics: Analysis of cost/demand functions, pricin