- Joel Busch
- Caroline Chen
- Kelly Gaffaney
- Kenneth Guilfoyle
- Matt Haag
- Jill Harding
- David Neighbors
- Annette Nellen
- Kimberley Peterson
- Eric Ryan
- William Skinner
- David Spence
- Julia Ushakova-Stein
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.
Before starting at SJSU this fall, Caroline was the Director of the Low Income Tax Clinic at Santa Clara Law, where she supervised students providing pro bono services and representation before the IRS for low-income taxpayers for the 5 years. She was also an Assistant Clinical Professor of Law and taught Federal Income Tax, International Tax and Tax Practice & Procedure.
Before creating the Tax Clinic, Caroline was a senior attorney at the Office of Chief Counsel of the Internal Revenue Service in San Jose for 13 years, primarily with the Large Business & International Division, specializing in international corporate tax. She has also been an adjunct professor at Golden Gate University, where she taught Federal Tax Practice and Procedure, and worked at Ernst & Young as a tax consultant before joining the IRS.
Caroline received her LL.M in Taxation from Georgetown University Law Center, her Juris Doctor from Washington College of Law, American University, and her B.S. from Rutgers, The State University of New Jersey. After receiving her J.D., she clerked for the Honorable Deborah Robinson of the United States District Court for the District of Columbia.
SJSU website: http://www.sjsu.edu/people/caroline.chen/
Business Technology Partner
Technology Sector Leader - West
Deloitte Tax LLP
Kelly has been providing innovative tax solutions and quality client service to taxpayers for 20 years. She has served both private and publicly-held companies from start-ups to large multinational corporations primarily in the technology, life sciences and manufacturing industries. She specializes in accounting for income taxes, consolidated tax returns, corporate reorganizations, and accounting methods. Kelly works with several multinational companies and teams within Deloitte’s international worldwide tax network to identify and implement worldwide tax efficient strategies as well as the overall necessary transfer pricing for companies in multijurisdictional locations. Kelly has extensive experience supporting her clients’ efforts to mitigate their overall effective tax rates and improve operating cash flow. The majority of Kelly’s career has been spent serving clients in Silicon Valley with the exception of two years where she served in Deloitte’s National Tax Office in Washington, D.C. While in DC, she collaborated with various firm national tax specialists in developing innovative tax planning opportunities and alternatives for clients’ business needs.
PROFESSIONAL QUALIFICATION AND AFFILIATIONS
Kelly received her Bachelor of Science in Accounting from Saint Mary’s College of California and her Masters in Taxation from Golden Gate University. Kelly is a licensed CPA in California and is a member of the AICPA and the California Society of CPAs.
Expatriate Services Practice Leader, BDO
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
LinkedIn Bio: http://www.linkedin.com/in/matt-haag-2621213
VP Corporate Tax - Synopsys, Inc.
BUS 225S Consolidated Returns
Jill Harding is the VP Corporate Tax at Synopsys, Inc., based in Mountain View. As the world’s 15th largest software company with over 13 thousand employees in over 30 countries, Synopsys is an innovative and dynamic company.
Prior to joining Synopsys, Ms. Harding was a Managing Director with Alvarez and Marsal Taxand LLC where she advised clients on acquisition structuring, tax due diligence, post-acquisition integration, legal entity rationalization, consolidated return issues, internal restructuring, cash repatriation planning, IP migration, debt restructuring, supply chain planning and optimization, spin-offs, inversions, and post-TCJA planning.
Prior to joining A&M, Ms. Harding was with Ernst & Young's national office in Washington, D.C., and transaction advisory services group in San Jose, CA.
With more than 18 years of transactional tax experience serving, mid-market corporations, Fortune 500 corporations and private equity funds, Ms. Harding has extensive experience addressing complex transaction tax issues for corporations and flow-through entities in a variety of industries with a focus on technology and life sciences industry sectors.
Ms. Harding earned a bachelor’s degree in psychology from the University of Guelph, in Ontario, Canada, her Juris Doctor from Michigan State University and her LL.M. from New York University. She is a member of the Pennsylvania bar.
Ms. Harding is a frequent speaker for the Tax Executives Institute, Practicing Law Institute and Bloomberg/BNA and has authored articles for the Practicing Law Institute.
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 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
BUS 225I Tax Practices, Penalties and Procedures
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, DLA Piper
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, 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.
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.
Associate | Fenwick & West LLP
Julia Ushakova-Stein focuses her practice on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, M&A, and transfer pricing. She represents clients from a diverse set of industries and geographic areas. She has represented a number of Fortune 500 companies in U.S. federal income tax matters and has successfully represented clients in federal tax controversies at all levels.
Julia was honored as one of the top 40 lawyers under 40 by the American Bar Association in 2018 and was the only person to win Euromoney’s Women in Business Law’s AmericasRising Star in Tax award in 2017. She appears in Euromoney’s 2018 and 2017 Expert Guides: Rising Stars in the Tax category and International Tax Review’s 2017 “Women in Tax Leaders.” Julia was also recognized by California Super Lawyers as a Rising Star in 2018 and shortlisted in the Best in Tax and Tax Disputes category for Euromoney’s 2018 Americas Rising Star Awards.
Julia regularly speaks at major tax conferences for professional tax groups, including for the International Fiscal Association, International Tax Review, and Euromoney, and regularly publishes articles relating to international tax.
Julia received her J.D. from the University of California, Berkeley, School of Law (Boalt Hall), where she served as the Supervising, Development, and Executive Editor for the Berkeley Business Law Journal. She received her B.S.B.A., summa cum laude, in accounting from the University of Arizona, Eller College of Management.