 Mark is a tax director in the national Global Enterprise Methods and Systems (GEMS) practice. Within GEMS, Mark has been instrumental in developing the GEMS holistic approach to assessing, developing and implementing tax-aligned business processes. This holistic approach begins by understanding the client’s business strategy and then applying tax technical, operational and project management skills to achieve structural tax efficiency within a global enterprise’s core operations. Mark’s primary area of specialization is with tax-aligned supply chains.
Mark has served as a tax advisor for more than 14 years. Prior to joining GEMS, Mark’s practice focused on international tax planning and compliance for U.S. and foreign-based multinational corporations in such areas as U.S. deferral (subpart F), foreign tax credits, withholding taxes, permanent establishments, export tax incentives under the FSC and ETI regimes, transfer pricing, and cross-border structuring and mergers and acquisitions.
A lawyer, Mark is admitted to practice in California and Pennsylvania, as well as before various federal courts, including the U.S. Tax Court. He earned his Master of Laws in business and taxation from the University of the Pacific, McGeorge School of Law, his Juris Doctor from Santa Clara University School of Law, and his Bachelor of Arts in history from Northwestern University. Mark is active in the taxation section of the State Bar of California, where he is currently a member of the section’s Executive Committee and is a past chair of the International Tax Committee. Mark is also a member and active speaker in the tax section of the American Bar Association.
Mark has published several articles in the California Tax Lawyer on such topics as the development of the application of the permanent establishment concept to electronic commerce, and issues related to how income earned from services performed electronically is sourced for U.S. tax purposes. His recent publications include:
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“A Tax-Aligned Approach to SCM,” Supply Chain Management Review (April 2005)
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“Proposed Cost Sharing Regulations: Are They A Realistic Alternative,” Tax Notes (October 10, 2005)
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