- Joel Busch
- Danni Sternfeld Dunn
- Fred Foldvary
- Vince Fong
- Kenneth Guilfoyle
- Matt Haag
- Daniela Ielceanu
- Marios Karayannis
- David Neighbors
- Annette Nellen
- Kimberley Peterson
- William Skinner
- Eric Ryan
- Jeff Sokol
- David Spence
Bus 223G Taxation of Business Entities
Bus 223B Taxation of Partnerships
Bus 227C Tax Symposium
Joel Busch is an assistant professor at San Jose State University. Prior to joining the faculty at SJSU, Joel spent over a decade at Granite Construction Incorporated where he was in charge of federal, state and local tax audits, appeals, research and planning. In addition, Joel was responsible for the creation, implementation and instruction of in-house tax education for the organization as well as representing the company in numerous tax legislation efforts and tax regulation reforms. Joel then spent the following seven years as a tax consultant, representing businesses and individuals on all facets of taxation – including income, sales/use, employment and property tax matters.
Joel has formerly served as Vice-Chair of the Tax Committee of the California Construction and Industrial Materials Association as well as an alternate board member of the California Taxpayers Association. He has been a guest speaker at various trade association tax seminars and has been an invited author in the area of privately-contracted tax consultants by governmental tax agencies based on his spearheading of successful legislative reforms in the area in California in partnership with the California Assessors’ Association.
Joel is a proud alumnus of San Jose State University – having received both a BS in Accounting and a MS in Taxation from SJSU. In addition, he has a JD from the Monterey College of Law. He is licensed in California as both a CPA and an attorney.
Partner,Transaction Advisory Services
Ernst & Young LLP
Bus 223C Taxation of Corporations and Shareholders
Bus 225B Taxation of Corporate Reorganizations
Bus 225S Consolidated Returns
Danni is a tax Partner in the Ernst & Young Transaction Advisory Services group. She has over 24 years of experience specializing in the taxation of corporate acquisitions, dispositions, reorganizations, post-merger integration, spin-offs, joint ventures, debt workouts, consolidated returns and cross boarder tax planning. Her industry focus has been on global high-technology companies and bio-technology companies.
Prior to joining Ernst & Young, Danni was with PricewaterhouseCoopers where she was the leader of the San Francisco Mergers and Acquisitions tax practice. During her career at PricewaterhouseCoopers, Danni worked in the San Francisco, San Jose and Washington National Tax Services offices.
Danni is a writer, instructor, and speaker in the area of merger and acquisitions and consolidated returns. She is an adjunct professor to San Jose State University and Golden Gate University. She is a continuing contributing author to Practicing Law Institute's TaxStrategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures,Financings,Reorganizations, and Restructurings.
Danni received her B.A. degree in Philosophy from the University of California, Berkeley. She received her J.D. degree and Masters in Business Administration from the University of California, Davis. Danni is a member of the California Bar Association.
Adjunct Faculty SJSU Economics Department; previously faculty at Santa Clara University
BUS 223H- Tax Policy Capstone (co-teaching)
Fred E. Foldvary received his B.A. in economics from the University of California at Berkeley, and his M.A. and Ph.D. in economics from George Mason University. He has taught economics at the Latvian University of Agriculture, Virginia Tech, John F. Kennedy University, California State University East Bay, the University of California at Berkeley Extension, Santa Clara University, and currently at San Jose State University.
Foldvary is the author of The Soul of Liberty, Public Goods and Private Communities, Dictionary of Free Market Economics . He edited and contributed to Beyond Neoclassical Economics and, with Dan Klein, The Half-Life of Policy Rationales. Foldvary's areas of research include public finance, governance, ethical philosophy, and land economics.
Vince Fong came to the United States when he was 10 and has lived in the Bay Area since. He attended UC Berkeley where he earned an undergraduate degree in engineering, an MBA, and a law degree (JD). After all that diverse education, Vince decided the best way to find some synergy in his education and his personal interest in optimization and minimization (operations research) would be in the field of taxation. He joined Arthur Andersen in San Francisco in 1975. In 1978 he joined Memorex to learn international tax. After a few of years of learning under some great mentors, Vince became the Manager for Research and Planning at Varian and shortly after that, set up his first tax department as Tax Director at Atari. In 1982, he had the opportunity to once again set up a tax department, this time for ComputerLand. In 1988, he was recruited to head up the tax department for Levi Strauss. At Levi Strauss, he began experimenting with how to a create high performance tax department at a time when the concept of outsourcing was not known and no one would have predicted that it could ever happen to a corporate tax department. He retired from Levi Strauss in 2004.
In 2010, Vince made the observation that most tax people, when they start out, do not know what it takes to reach their full potential and that it is often 6-10 years later, if they are lucky, before they find out. So, Vince decided it would be a wonderful idea to create a course to teach this very vague topic to tax students and says he was fortunate to have received encouragement and support from Professor Nellen to teach it as an experimental course three times before Fall 2012 when it was first taught as an official MST course and Vince became an adjunct professor in the SJSU MST Program.
In addition to teaching, Vince devotes time to his family. He is pictured here with his grandson Bryce.
Expatriate Services Practice Leader, BDO
Bus 225X International Taxation – US & Foreign Individuals
Kenneth Guilfoyle has a master’s degree in International Business Administration from the University of South Carolina and joined BDO national expatriate services group, with over 25 years of professional experience including 10 years of expatriate practice experience in Tokyo Japan, London United Kingdom, and Athens Greece. Ken knows firsthand the challenges faced by international assignees, employers and high net worth individuals who reside outside the U.S. Ken has worked both in industry and big six public accounting firms. Ken’s strengths include relationship management, international business and taxation, strategic human resource management consulting, global mobility benefits and taxation.
- Society for Human Resource Management American Institute of Certified Public Accountants
- Delaware CPA Society
- Fellow, Life Management Institute (Insurance Industry Designation)
- Bachelor of Arts, Monmouth University
- Int’l Masters of Business Administration, University of South Carolina
CPA Permit: Delaware and South Carolina
BUS 225U - Fundamentals of Transfer Pricing (co-teaching)
LinkedIn Bio: http://www.linkedin.com/in/matt-haag-2621213
Director, PricewaterhouseCoopers LLP
Daniela Ielceanu is a transfer pricing economist and a Director in PricewaterhouseCoopers' San Jose office. Daniela assists in advising multinational companies on matters related to determining, evaluating, planning for, and documenting intercompany pricing arrangements including but not limited to: transfers of intangible property and cost sharing arrangements, in particular in association with the design and implementation of structural business changes; management service fee allocations; intercompany guarantee fees; investment management fee splits; and various revenue and profit split analyses for intercompany services. She has been involved in the negotiation of Advanced Pricing Agreements with the IRS and matters related to resolving controversy issues with tax authorities in audit defense environments. Daniela's experience includes work with companies in the semiconductor, semiconductor design, software,bio pharma, medical devices, and financial services industries.
Daniela is a member of the American Society of Appraisers. She holds a Ph.D. degree in Economics (Game Theory) from the University of North Carolina at Chapel Hill, U.S.
Recent working papers/publications include:
"Transfer Pricing for Financial Services Companies," Adam Katz; Aamer Rafiq; Stanley J. Hales; Ryann Thomas; Daniela Ielceanu and others; book in progress, to be published by PricewaterhouseCoopers in 2011
- "Estimating Guarantee Fees under the Loss Given Default Framework," Stanley J. Hales, Dan Axelsen, and Daniela Ielceanu, 2008; Tax Management International Journal, Vol.39, No.8, August 13, 2010
- "On the Economics of the Fees Charged by Investment Managers of Separate Managed Accounts - Does Performance Matter?" PricewaterhouseCoopers' PKN United States, March 2009; Stanley J. Hales, Mac Calva, and Daniela Ielceanu
- "Industry Analyses for Transfer Pricing Purposes: A New Look at the Old Porter Five Framework" (co-author); internal PricewaterhouseCoopers training materials; 2008
- “Comments on Proposed Regulation §1.482-7” (co-author), submitted to the Department of the Treasury and the Internal Revenue Service and prepared on behalf of the Membership of the United States Council for International Business on the proposed U.S. regulations on cost sharing of intellectual property development among controlled parties; 2006
"The "What," the "Why," and the "How" of Capital Intensity Adjustments and Inventory Accounting Method Adjustments in Transfer Pricing Analyses" (co-author), internal PricewaterhouseCoopers training material; 2006
Senior Transfer Pricing Economist for PricewaterhouseCoopers LLP
BUS 225U - Fundamentals of Transfer Pricing
Marios Karayannis is a Partner at PwC in San Jose. He leads the firm's West Region Transfer Pricing Practice and the Global Transfer Pricing Services for Technology Industry clients. He is the Senior Transfer Pricing Economist for PricewaterhouseCoopers LLP on the West Coast with 20 years of experience. He advises multinational companies on matters relating to determining, evaluating, or documenting intercompany pricing arrangements, and resolving controversy issues with U.S. and foreign tax authorities in the Advance Pricing Agreement, Competent Authority, or audit defense environment. He has also been engaged by counsel to provide expert advice on intercompany pricing matters during IRS audits and in bankruptcy proceedings.
His experience covers nearly all areas of intercompany arrangements, with principal focus on transfers of intellectual property transactions, cost sharing arrangements, and transactions related to the design and implementation of business structural change. His principal clients consist of U.S.-based and foreign-based multinational companies in the technology sector, including semiconductor, semiconductor design, networking equipment, electronic manufacturing services, wireless communications, computer software, internet and biotechnology companies.
Dr. Karayannis has published studies and articles on transfer pricing, tax policy, and financial economics, and speaks frequently on related topics at internal and external conferences around the country and internationally. He holds M.A. and Ph.D. degrees from the University of Virginia.
Partner Tax- Gallina LLP
David is the partner in charge of SingerLewak's Silicon Valley Tax Practice and has more than 20 years of business experience in Silicon Valley specializing in corporate and individual tax compliance and planning. David has experience in the areas of compensation planning, start-up and emerging growth issues, mergers and acquisitions, accounting for income taxes, research credits and stock option planning.
Prior to joining SingerLewak, David was with KPMG Peat Marwick and Ernst and Young in San José. He works with high net worth individuals, closely held businesses, partnerships, limited liability companies and fiduciaries. An area native, David graduated from San José State University with a Bachelor of Science degree in Business with an Accounting emphasis and a Master’s degree in Taxation.
David is involved in many professional and civic organizations in the community. He is an active member of the AICPA and President of the Silicon Valley/San José Chapter of the California Society of Certified Public Accountants. He is a member of the adjunct faculty at San José State University's Lucas Graduate School of Business; an elected member of the Governing Board of the Berryessa Union School District; a member of the Board of Trustees for The National Hispanic University Foundation and the Beta Alpha Psi Scholarship Committee at San José State University. Additionally, he is an appointed member of the East Side Union High School District’s Audit Committee. He regularly volunteers his time helping local non-profit organizations with their annual tax filings and has served as a board member of the Big Brothers and Sisters of Santa Clara County and Alum Rock Counseling Center.
Professor and MST Program Director
San José State University
BUS 223A - Tax Research & Decision Making
BUS 223F - Tax Accounting Methods/Periods
BUS 225F - State Taxation Fundamentals
BUS 223H - Tax Policy Capstone
BUS 225H - Taxation of Property Transactions
BUS 225K - Advanced Individual Taxes
BUS 227B - Ethics for Tax Practitioners (1 unit, online)
BUS 227D - Employment Taxation and the Modern Workforce (1 unit)
Annette has been at SJSU since 1990. Prior to coming to SJSU, she was with the Internal Revenue Service and Ernst & Young. Annette is active in the tax sections of the AICPA and ABA. She is currently a member of the AICPA's Individual Taxation Technical Resource Panel. She is the incoming chair of the Tax Policy & Legislation Committee of the California Bar Association. She has previously served on the Tax Executive Committee of the AICPA and chaired the Sales, Exchanges & Basis Committee of the ABA Tax Section.
Annette is a frequent speaker and author on tax policy and reform, high tech tax matters, accounting methods and taxation of e-commerce. She writes monthly articles for the AICPA TaxInsider and AICPA Corporate Taxation Insider (online newsletters). She is the main author of BNA's Tax Management Portfolio No. 533, Amortization of Intangibles. She created and maintains the 21 st Century Taxation website and blog.
Annette has a BS in Accounting from CSU, Northridge, an MBA from Pepperdine, and a JD from Loyola Law School. She is a California CPA and attorney.
Annette's website, with lots of tax information, MST program information, as well as information on the history of SJSU can be found at: http://www.sjsu.edu/people/annette.nellen/website/.
Director- Tax Controversy Services, Deloitte
Kim joined Deloitte in 2008 in the West Region Tax Controversy Services practice where
she represents small and large corporate clients at the examination and appeals levels
of the IRS. Prior to joining the organization, she was Deputy Area Counsel, Strategic
Litigation for IRS Chief Counsel, where she was responsible for the Significant Case
Litigation program for IRS Chief Counsel’s Communications, Technology and Media Division.
During her 13-year tenure with IRS Chief Counsel, Kim spent a significant amount of
time advising large case agents, international examiners, and appeals officers in
some of the IRS’ largest international and domestic corporate issues, including representing
the government in DHL v. Commissioner (transfer pricing) and Microsoft v. Commissioner
(FSC export property). In 2008, Kim supervised the trial in Veritas Software Corporation
v. Commissioner (cost sharing buy-in).
- Deputy Area Counsel, Strategic Litigation – IRS Chief Counsel, San Jose
- Associate Area Counsel, LMSB – IRS Chief Counsel, San Jose
- International Field Counsel, LMSB – IRS Chief Counsel, San Jose
- Senior Tax Consultant (1992 – 1995) – Deloitte & Touche LLP, San Jose
- State Bar of California
- United States Tax Court Admission to Practice
- IRS Chief Counsel National Litigation Award – 1997 and 1999
- IRS Chief Counsel Western Region Litigation Award – 1999
- IRS Chief Counsel National Training Instructor, Working with Expert Witnesses and Effective and Efficient Tax Court Discovery
- BS – University of California, Berkeley
- JD – University of Arizona, James E. Rogers College of Law
Partner, Tax Group of Fenwick & West LLP
Will Skinner focuses his practice on U.S. corporate tax matters, including representation of multinational corporations in international tax consulting and tax controversy, and representation of companies in Silicon Valley M&A transactions.
In his international tax practice, he develops and stress-tests customized tax planning to meet client objectives, and has successfully defended several corporations before the IRS. He has experience representing both outbound and inbound taxpayers, and has particular industry experience with software, hardware and other high technology firms and pharmaceutical and life sciences companies. He also has specialized expertise in foreign currency and financial products tax issues and federal tax controversies involving the domestic production activities deduction (Section 199).
In his transactional tax practice, Will has led the tax representation on many successfully completed transactions, including public and private company acquisitions, tax-free reorganizations (including cross-border reorganizations), leveraged buy-outs, formations and spin-outs, and S Corp and LLC transactions. He has experience with a range of financial products transactions, including issuances of convertible debt, hedge fund formation, and use of derivatives to monetize appreciated stock positions.
With intense client focus a hallmark of his practice, Will has been recognized by California Super Lawyers as a rising star in tax. He is sought out for the clarity and thoroughness of his writing and speaking, and regularly presents at industry educational programs, such as Bloomberg BNA, Strafford, TEI, and IFA events. He has taught international tax at San Jose State University for several years. A prolific writer, Will has published numerous articles, including in the Journal of Taxation, Journal of Corporate Taxation, International Tax Journal and PLI’s Corporate Tax Practice Series. He is the author of a treatise on cross-border spin-offs for RIA’s Checkpoint Catalyst.
Will served as a law clerk for the Honorable Carlos T. Bea on the U.S. Circuit Court of Appeals for the Ninth Circuit.
Will graduated with a J.D., with distinction from Stanford Law School in 2005, where he was a member of the Stanford Law Review. He received a B.A. in history in 2001 from the University of California, Berkeley.
Partner, DLA Piper
Bus 225V Tax Considerations for High Tech Companies
Eric D. Ryan concentrates in international tax planning, transfer pricing, post merger integration of legal entities and operations and tax controversy. He has over 25 years of experience, both as a tax partner advisor and an internal corporate tax director, on key international tax structuring issues. His clients are primarily in the high technology industry, including software, hardware, semiconductors and life sciences companies.
His experience includes advising clients in choice of location for their operations; conducting direct negotiations for tax holidays in countries such as Switzerland, Singapore and others; advising on intercompany arrangements that minimize Subpart F and similar tax issues; and advising on intercompany economic terms that seek to maximize profits in appropriate jurisdictions. He advises on the use of holding companies, the valuation of transfer of tangible and intangible property and the establishment of cost-sharing operations. Mr. Ryan is experienced in developments of advice pricing agreements (APA’s) and intercompany debt and equity.
On behalf of the Government of the United States Virgin Islands, Mr. Ryan worked to obtain the favorable guidance from the US Treasury and Internal Revenue Service ultimately contained within Notice 2006-76, relating to the qualification of certain e-commerce business models for income tax exemptions in the USVI.
As tax director for Apple Computer, Inc., Mr. Ryan was responsible for the worldwide tax planning, compliance and audit defense activity for this Fortune 100 company operating in more than 30 countries. He led that company’s efforts to respond to the IRS at the exam, appeals and Tax Court levels. Mr. Ryan was responsible for the efforts which led to the favorable Tax Court decision regarding Apple's inclusion of stock option compensation in the qualifying base for R&E credits (Apple Computer, Inc. v. Commissioner, 98 T.C. No. 18 (1992)). He was also the architect of the world’s first APA in 1991, between the US and Australia, and later for others with Japan and Canada.
Mr. Ryan is listed as one of the pre-eminent practitioners in the Guide to the Worlds' Leading Transfer Pricing Advisors, published by Euromoney. In 2006, he was recognized as one of the top tax lawyers in the Bay Area in a study published by Bay Area Lawyer magazine. He is a frequent speaker on international tax matters for several organizations, including the California Bar Association Tax Section, the Asia Tax Executives Forum, and the Council for International Tax Education (CITE).
Mr. Ryan is a Pro Bono Coordinator for the East Palo Alto office.
On behalf of the Government of the United States Virgin Islands, Eric worked to obtain the favorable guidance from the US Treasury and Internal Revenue Service ultimately contained within Notice 2006-76, relating to the qualification of certain e-commerce business models for income tax exemptions in the USVI.
- Partner, Taxation, PricewaterhouseCoopers LLP (1994 – 2004)
- Director of Taxes, Apple Computer (1983 – 1994)
As tax director for Apple Computer, Inc., Eric was responsible for the worldwide tax planning, compliance and audit defense activity for this Fortune 100 company operating in more than 30 countries. He led that company’s efforts to respond to the IRS at the exam, appeals and Tax Court levels. Eric was responsible for the efforts which led to the favorable Tax Court decision regarding Apple's inclusion of stock option compensation in the qualifying base for R&E credits (Apple Computer, Inc. v. Commissioner, 98 T.C. No. 18 (1992)). He was also the architect of the world’s first APA in 1991, between the US and Australia, and later for others with Japan and Canada.
COURTS AND FORUMS
- United States Tax Court
Eric is listed as one of the pre-eminent practitioners in the Guide to the Worlds' Leading Transfer Pricing Advisors, published by Euromoney. In 2006, he was recognized as one of the top tax lawyers in the Bay Area in a study published by Bay Area Lawyer magazine.
CIVIC AND CHARITABLE
- Past President, Tax Executives Institute, Santa Clara Chapter
- Advisory Board, Practical US/International Tax Strategies
Partner, Deloitte Tax LLP
Bus 225L Accounting for Income Taxes
Jeff has over fourteen years of public accounting experience with Deloitte working primarily with high technology and manufacturing clients including Electronic Arts, Intel, Intuit, Synnex and Yahoo!. He has experience serving both start-ups and large, multinational corporations; he has worked with both private organizations and publicly held companies. Jeff spent two years in Deloitte's National Tax Office in Washington, D.C. where he was a member of the Subchapter C group. He has practiced in Deloitte's San Jose office for the past six years.
Jeff received his B.S. in Accounting from Cal Poly San Luis Obispo, and his M.B.T. from the University of Southern California. Jeff is a California CPA.
Bus. 225A - Taxation of Estates and Trusts
David Spence is an attorney, practicing with Royse Law Firm in San Jose and Palo Alto. David assists clients of the firm in preserving, protecting and transitioning their wealth.
David's technical focus areas are estate & gift taxation, and related estate, trust, probate and business law. David has provided tax and wealth management advice and counsel to some of the largest estates in the world. In addition, he has represented clients before many different courts and other government entities, including the Internal Revenue Service and United States Tax Court. He was co-counsel of record in successful representation of the taxpayer in the case of Paullus v. Commissioner, T.C. Memo 1996-419, 72 TCM 636 (U.S. Tax Court Sept. 17, 1996).
David began his professional career in 1986 with the tax department of KPMG. Since then, David has practiced with prominent law firms and accounting firms in Silicon Valley, including Berliner Cohen and Deloitte & Touche. Immediately prior to joining Royse Law Firm, David was with Wells Fargo Private Bank, where he was Regional Trust Manager and Senior Wealth Management Specialist.
David is an active public speaker, and has lectured on numerous occasions in continuing education programs for attorneys, CPAs, and other financial professionals. He was a recurring guest expert on estate planning and tax law for the legal education radio program, "Legal Incite" on KNEW AM 910 in San Francisco. Mr. Spence has also presented for professional education programs sponsored by the Santa Clara County Bar Association, the Silicon Valley Bar Association, the Santa Cruz County Estate Planning Council, Lorman Education Services, Deloitte & Touche LLP, Wells Fargo Bank, Lincoln Law School, and Sacramento State University.
David received a Bachelor of Science in Accounting, a Master of Accountancy in Taxation, and a Juris Doctor degree from Brigham Young University, where he was a member of the Moot Court Board and Beta Alpha Psi. He is licensed to practice before The Supreme Court of California, The United States District Court for the Northern District of California, and The United States Tax Court. He is a member of the State Bar of California Tax Section, the Estate and Trust Section, and the Business Law Section, and is a member of the Palo Alto Area Bar Association.