David A. Blackett
West Hollywood
Overview
7
7
years of professional experience
Work History
International Income Tax Manager
Ryan LLC
07.2023 - Current
- FTC Planning: Ensure tax credits are fully utilized, create interco royalties, sale-leaseback transactions, and optimize 861 expense allocation and apportionment
- FDII Planning: Identify additional FDDEI from trial balances, optimize COGS and SG&A allocation (especially interest) and apportionment, and optimize QBAI in calculation
- BEAT Planning: Ensure interco loans are timed to avoid BEAT, time fixed asset placed in service timeline to optimize BEAT percentage threshold
- Pillar Two Planning: Develop internal model based on BNA source for clients, serve as source for firm Pillar Two developments.
International Tax Manager - Financial Services
PricewaterhouseCoopers LLP
01.2022 - 07.2023
- Supervise senior associates, associates, interns, and offshore team members on their day to day work assignments.
- Specialize in compliance of private equity owned portco groups.
- Tax compliance and work paper review for Form 1042, 5471, 8858, and 8865.
- Tax consulting on wide range of issues including FTC creditability, substantial contribution, filing requirements based on structuring, loss planning for partnerships
- Correspond with tax teams in foreign countries on client needs.
- Manage budget on projects and consistently bring in at or below targets.
International Tax Senior
Deloitte Tax LLP
01.2020 - 01.2022
- Prepared and reviewed international tax returns and work papers (Forms 5471, 8858, 8865, 1118, 899X’s etc.).
- Received large client data files and extracted relevant information for reporting requirements.
- Trained associates and interns on tax software functionality.
- Prepared power point decks for consulting projects involving restructuring and IP transfers.
- Communicated with international counterparts for foreign tax considerations of transactions.
- Reviewed international tax calculations in connections with audits.
Tax Associate
PricewaterhouseCoopers LLP
06.2017 - 12.2019
- Prepared federal, state, and international tax returns and all related work papers for private companies.
- Performed taxable income calculations and calculated depreciation.
- Audited and prepared tax provisions and documented support in audit software.
- Responded to federal and state tax authorities to resolve disputes on behalf of clients.
- Ensure tax returns were submitted to IRS through tax software or mail.
- Consistantly among highest utilized associates in group.
Education
NORTHWESTERN LAW -
LL.M. In Taxation
Chicago, ILCASE WESTERN LAW -
Juris Doctor
Cleveland, OHBALDWIN WALLACE UNIVERSITY -
B.A. In Accounting & Finance
Berea, OHSkills
State of California, Passed Feb 24 Exam, Awaiting Bar Card
State of Illinois, Reg No 6332071
State of New York, Reg No 5549894
Summary
David Blackett is an attorney licensed to practice in California (pending bar card), Illinois, and New York. He has experience representing large corporate clients in all their tax planning and compliance needs. He has specialized in International Tax and is familiar with planning and compliance in primarily outbound corporations. He began his career as an accountant and is currently eligible and in the process of obtaining his CPA license.
CPA license
State of California, Candidate, ID #DZ173073
Internships
The Sherwin Williams Company, Law Clerk, Summer 2015-Spring 2016
United States-Canada Law Journal, Editor, Fall 2014-Spring 2016
Western District of Pennsylvania United States Bankruptcy Court, Judicial Extern, Summer 2014
Joseph D. Carney & Associates LLP, Legal Intern, Spring 2012-Summer 2013
Languages
English (Native)
German (Student, Basic)
Timeline
International Income Tax Manager
Ryan LLC
07.2023 - Current
International Tax Manager - Financial Services
PricewaterhouseCoopers LLP
01.2022 - 07.2023
International Tax Senior
Deloitte Tax LLP
01.2020 - 01.2022
Tax Associate
PricewaterhouseCoopers LLP
06.2017 - 12.2019
NORTHWESTERN LAW -
LL.M. In Taxation
CASE WESTERN LAW -
Juris Doctor
BALDWIN WALLACE UNIVERSITY -
B.A. In Accounting & Finance