Todd is a senior manager in KPMG’s International Tax practice, with more than thirteen years of experience in international tax consulting and planning. Prior to joining KPMG, Todd worked in the tax department of the Atlanta office of a national law firm and the Chicago office of another Big 4 accounting firm.
Todd advises both domestic and foreign companies on their investments and operations into and out of the United States. Todd has advised clients on a variety of U.S. federal income tax implications arising from their multinational operations and investments, including such cross-border tax issues as subpart F and section 956 inclusions, foreign tax credits, FIRPTA, section 367 outbound transfers to foreign corporations, permanent establishments and U.S. trade or businesses, FATCA and U.S. domestic withholding tax implications. Todd also advises domestic and international companies on a wide array of international tax issues and planning strategies, including U.S. tax treaty analysis, minimization of U.S. tax from the ownership and sale of U.S. real estate, tax effects of mergers, acquisitions and divestitures, and assisting clients with designing and implementing acquisition tax planning strategies to reduce a company’s effective tax rate.
Todd provides advice on a range of U.S. cross-border tax issues, including rules dealing with the ownership of U.S. real property interests, cross-border debt financing, foreign tax credit utilization, anti-deferral, taxation of a foreign corporation’s U.S. business operations and the application of U.S. income tax treaties.
Todd has spoken on a variety of topics including structuring foreign investments into the United States, foreign exchange rate gain and loss and tax considerations for the sale of businesses.