Partner, PricewaterhouseCoopers LLP, leads the International Tax Services group in Cleveland and is national leader of PwC’s U.S. Outbound team. The U.S. Outbound team designs and implements foreign debt restructuring and holding company solutions, and helps the firm’s U.S. clients optimize their use of foreign tax credits. Michael has extensive experience in the development of strategies to increase foreign source income, and to minimize foreign source expenses (stewardship and SG&A studies, CFC netting rule computations, interest and R&D expense apportionment, etc.). He has also has worked extensively on tax efficient foreign acquisition structuring and integration.
Michael has twenty four years of international tax experience serving numerous U.S. and foreign-based multinationals. From July 1990 to September 1991, Michael was on special assignment in the firm’s New York office managing the U.S. international tax desk.
Michael has made frequent speeches and has been an author on a variety of international tax subjects. He is also Adjunct Professor of the Masters level international tax course at The University of Akron.
As Ernst & Young LLP’s International Tax Services group market leader for Northeast Ohio, Alan serves a number of U.S. and foreign based companies. He has over 27 years experience in taxation, the last 20 focused on international taxation matters affecting multinational enterprises. He has extensive experience in U.S. and foreign country transfer pricing matters, supply-chain planning, cross-border financing transactions, repatriation, and foreign tax credit planning.
Alan has served clients in a variety of industries, principally manufacturing, food and beverage, pharmaceutical and medical devices, and natural resources.
Alan has been a frequent speaker at seminars sponsored by the Tax Executives Institute, the World Trade Institute, and ATLAS/CITE, as well as an instructor in International Taxation classes for DePaul and the University of Cincinnati. He has published or co-authored several articles on topics including source and character of income, Passive Foreign Investment Companies, transfer pricing, and financing and structuring cross-border investments.
Alan became a Certified Public Accountant in 1983 in Alabama and is also certified in Ohio and North Carolina. He is a member of several professional organizations, including the American Institute of CPAs.
Dean C. Pontius is a Partner in the International Tax Services group of PricewaterhouseCoopers LLP based in Cleveland, Ohio. He was admitted to the partnership on July 1, 2006. Although his experience covers a broad range of international tax issues, Dean specializes in assisting U.S. based multinationals with U.S. and foreign tax restructuring, IRS reporting issues regarding foreign investment, and issues involving U.S. foreign tax credits. Dean joined the Firm in 1993, and served 1 1/2 years in PwC’s Washington National Tax Practice. He also served as International Tax Manager for NACCO Industries, Inc. from 1996-1998. In his current role with PwC in Cleveland, Dean actively serves a diverse client base of multinational corporations including Parker Hannifin, Lubrizol, and United Technologies (Hartford, CT).
In addition to his client responsibilities, Dean is a frequent instructor of international tax classes for PricewaterhouseCoopers training programs, various professional seminars in Northeast Ohio, and serves on the International Tax Services Outbound Solutions National Team for PricewaterhouseCoopers. Dean is also a co-instructor for the US Tax and Transnational Operations course in The University of Akron’s Masters of Taxation program.
Erik Rosenfeld is a director specializing in international tax issues with the PwC Cleveland office. He has been with PwC for 5 years and has over 10 years of work experience on primarily corporate tax matters involving U.S. based multinational corporations. Erik recently returned to Cleveland after spending two years in PwC’s Washington National Tax Services office. He specializes in international tax planning issues for U.S. and foreign multinational corporations and teaches regularly at PwC’s national training courses for tax specialists.
David B. Joranko is a Tax Partner in Ernst & Young’s Global Tax Analysis Group (GTAG), a sub-specialty group within Ernst & Young’s International Tax Service Line. Based in Cleveland, Dave has a national responsibility for assisting U.S. multinational businesses in determining and managing their U.S. tax attributes related to their international operations. Dave’s specific areas of focus include the U.S. foreign tax credit, U.S. export tax incentives (IC-DISC, FSC and ETI), and U.S. taxation of controlled foreign corporations and foreign branches. Dave has also assisted clients in implementing and calculating the U.S. Production Activities Deduction under Section 199.
Dave has been a frequent speaker for the Tax Executives Institute, FSC/DISC Tax Association, Council for International Tax Education and ATLAS. He authored the July 15, 1996 Tax Notes International article "A FSCful of Dollars: Maximizing FSC Benefits through Transaction Level Pricing" and the November 27, 2000 TNI article on the FSC Repeal and Extraterritorial Income Exclusion Act of 2000.
Brendan Daly joined PwC from Ernst & Young’s Northeast Ohio offices, where he was a Senior Manager in the firm’s Transfer Pricing group. He has considerable experience in advising multinational companies on transfer pricing matters, including assessing the transfer pricing implications of business restructurings, identifying tax planning opportunities, determining arm’s length pricing and assisting with the implementation of the same. His experience includes analyzing transfer pricing issues across a broad set of industries, including health care, specialty chemicals, automotive, alcoholic beverage, consumer products, metals and other manufacturing and distribution businesses. He has also represented multiple clients with tax controversies relating to their intercompany pricing. In addition to transfer pricing, Brendan has experience in a broad range of federal, state, and international tax areas, including mergers and acquisitions, FAS 109, and general tax accounting.
Chip Harter is a principal in the International Tax Services Practice of the Pricewaterhouse-Coopers LLP Washington National Tax Practice. He advises U.S. multinational companies on international tax planning, with a focus on crossborder financing issues. Mr. Harter joined PricewaterhouseCoopers in 1999 after having practiced tax law with Baker & McKenzie for 18 years. From 1989 through 1994, he was an Adjunct Professor of Taxation in the Graduate Tax Program of IIT Chicago-Kent College of Law.
Mr. Harter is a past Chair of the Financial Transactions Committee of the American Bar Association Section of Taxation. He regularly speaks and publishes on international and financial tax topics. Recent publications include “Observations on Disclosure, Transparency and Taxpayer Compliance,” Vol. 82, No. 3 TAXES, p. 129 (March 2004); “The Uncertain Application of the Corporate Tax Shelter Reporting Regulations to International Tax Planning,” in Vol. 1, No. 1 of Taxation of Global Transactions (CCH), p. 44 (Fall 2001); “International Tax Arbitrage: Is It A Problem? Whose Problem Is It?” in Vol. 41, No. 6 of the Tax Management Memorandum, p. 139 (April 24, 2000); and “The Subpart F Treatment of Financial Transactions and Hedges Entered into by Controlled Foreign Corporations,” in Vol. 38, No. 6 of the Tax Management Memorandum Corporate Tax and Business Planning Review, p. S-70 (March 17, 1997).
Mr. Harter earned a JD from the University of Chicago Law School in 1980, where he was Comments and Articles Editor on the University of Chicago Law Review, and graduated magna cum laude from Harvard College in 1977. Following law school, Mr. Harter clerked for The Honorable Thomas R. McMillen, United States District Judge for the Northern District of Illinois.
Jon Nagy is an International Tax Services (ITS) partner located in our Cleveland Office. Jon is one of six ITS partners fully dedicated to PwC’s national ITS Quantitative Solutions (ITS-QS) practice, leading engagements in connection with “the numbers” side of international tax solutions for top tier multinationals throughout the nation. Jon’s area of expertise includes foreign source income/repatriation/foreign tax credit modeling, IRC Section 861 expense allocation and apportionment solutions, Foreign Earnings and Profits Determination, IRC Section 987 Currency Gain and Loss Quantification, and comprehensive quantitative ITS planning.
While Jon is based out of Cleveland, he works with large US multinationals throughout the country. His ITS-QS team is made up of roughly 80 professionals fully dedicated to quantitative international tax solutions, working with top tier companies throughout the nation on ITS quantitative matters.
Adam Lechman is a Transfer Pricing Manager in PwC’s Cleveland office. He specializes in assisting U.S. based multinational corporations and foreign inbounds on transfer pricing matters, including establishing and implementing arm’s length pricing, identifying tax planning opportunities, identifying and managing transfer pricing risk, and dispute resolution. Adam also assists domestic companies on transfer pricing matters primarily related to business restructurings. His experience includes analyzing transfer pricing issues across a broad set of industries, including retail, education, media, automotive, specialty chemicals, and other manufacturing and distribution businesses.
Prior to joining PwC, Adam was an economist with the Institute for Defense Analyses, a federally funded research and development center in Alexandria, Virginia He became a Certified Public Accountant in 2001 and gained a broad range of experience in federal, state, and international tax areas as the owner of a local accounting firm and, more recently, at Ernst & Young.