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.
<Donald R. (Don) Longano, former Chief Tax Counsel to the House Ways and Means Committee, is a principal in the PricewaterhouseCoopers LLP Washington National Tax Services office. Mr. Longano is responsible for analyzing federal tax legislative and regulatory developments for many of the firm’s clients.
Prior to joining the legacy firm Price Waterhouse LLP in January 1995, Mr. Longano spent nearly ten years on the staff of the Committee on Ways and Means of the United States House of Representatives. From 1993 to 1995, in his most recent position as Chief Tax Counsel, he advised Democratic Members of the Committee on all federal taxation issues; coordinated tax policy development and production of legislation within the Committee; and participated in drafting legislation and Committee reports.
From 1985 to 1993, Mr. Longano was responsible for a wide range of substantive tax issues for the Committee staff, including international, corporate, partnership and insurance taxation. He was also extensively involved in the Tax Reform Act of 1986 and all subsequent revenue measures through the 103rd Congress.
Mr. Longano earned his LL.M. in taxation from the New York University School of Law (1982); his J.D. from the Georgetown University Law Center (1979); and his A.B. in Economics from the University of Notre Dame (1976).
Michael A. DiFronzo serves as a Principal in the Washington National Tax Office of PricewaterhouseCoopers LLP. In that role, Mr. DiFronzo serves as a global resource for the firm’s international tax practice. His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules. He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash repatriation and other planning issues.
Before joining PricewaterhouseCoopers, Mr. DiFronzo was a senior executive in the U.S. Treasury Department. He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical). In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues. Mr. DiFronzo served in that role from 2006 through 2010.
Prior to joining the Office of Chief Counsel, Internal Revenue Service, Mr. DiFronzo served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois. There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations. Mr. DiFronzo’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.
Mr. DiFronzo received an LL.M. in taxation from New York University School of Law, a J.D. from University of Montana School of Law, and a B.S. in Accounting from Montana State University. Mr. DiFronzo currently serves on the Board of International Tax Advisors and as a guest lecturer for New York University School of Law’s graduate tax program. Mr. DiFronzo also serves on the Board of Visitors for the University of Montana School of Law.
Mr. DiFronzo’s professional affiliations include the tax sections of the American Bar Association and the DC Bar Association, as well as the International Fiscal Association. He is the author of numerous articles on cross-border tax issues and a frequent speaker. Mr. DiFronzo is currently a member of the District of Columbia, Illinois, Montana and Nevada bar associations and is admitted to practice before the United States Tax Court. He is also licensed as a CPA.
Bill Hahn is the leader of the North American Automotive Transfer Pricing Practice for PwC and is a Principal based in the Detroit office. He has over 20 years of transfer pricing and valuation experience focused on the automotive and general manufacturing industries. In addition to automotive documentation, policy, APA and examination resolution projects for clients, Bill also established and managed a transfer pricing practice in Mexico City, Mexico, where he resided for three years. Bill has been recognized as one of the World’s Leading Transfer Pricing Advisors and is a frequent author and speaker.
Bill holds a B.A. in Economics from Northern Illinois University and an M.B.A. from the University of Illinois.
Karl Rotthfuss leads Ernst & Young’s Transfer Pricing Services in Ohio and Kentucky. He has substantial experience in developing and managing US, non-US, regional, global and state transfer pricing planning and documentation projects. In addition, Karl has extensive financial modeling capabilities including valuing and/or pricing exchanges involving subsidiaries, intellectual property, technology, trade names, tax attributes, business lines, services and other intangible property, employing various analytical approaches.
Karl has experience in developing and negotiating audit defense with US, non-US and state tax authorities, as well as Competent Authority proceedings. His project experience also includes most industries, including Chemicals. Firms range from start-ups to major multinational corporations.
Karl possesses a Bachelor’s degree in economics from Miami University (Ohio), a Master’s in geography from Montana State University and a Master’s and Ph.D. in economics from New York University.