Synopsis: Qualifications synopsis: [2021] Qualified, FedEx Services International Tax Accounting Advisor interviewed [2021] U.S. Treasury Office of Appeals, International Tax Law Specialist Grade 13 Deputy Director level three member panel interview [December 2020, Supervisory Sssociate Advocate TAS Area 2-Philadelphia Federal Government OPM Senior Executive ECQ "well qualified" rating (GS-15) Deputy Executive Director, Planning Analysis and Requirements Evaluative Directorate SME panel rated Schlegel series/grade eligible, Deputy Director, Legislative & Regulatory Coordination with Departmental Administration, OBPBA-SES-2019-1294. Global Tax & Legal "Deloitte model" business architecture, C-suite senior accounting executive, organization federal & multistate direct, indirect income compliance filings, financial statements & note disclosures in accordance with SEC, AICPA FASB standards, contested tax controversy administrative proceedings, civil & criminal federal government investigations, preservation & custody of transaction documents & supporting evidence organization finance KPI strategies, Deloitte FP&A tools, econometric modeling, budgeting, costing & planning, Short-term debt, long-term debt, restructure debt, collateral agreements Legal advise & consent due diligence & undertakings, organization good standing & governance review, nonprofit law & governance, FASB 2016-14 "Presentation of Financial Statements of Not-For-Profit Entities " federal, state & local regulatory compliance review federal agency exhaustion of administrative remedy hearings for federal appeal standing. Federal Administrative Agency Review: Kisor v. Wilke, 869 F.3d 1360 (Fed.Cir. 2017), 588 U.S. 139 S.Ct. 2400 (2019) 1933 sec act, 1934 sec act, intellectual properties law, government relations & affairs, Legislative advocacy & policy planning, organization review of federal, state & local planning coordination. Schlegel's Discussion of Qualifications: expertise (1) aicpa standards fasb asc 946 business development companies, Valuation of Private Equity and Venture Capital Firms (2019) (2) strategic planning design & implementation (3) U.S. domestic parent-subsidiary multi-jurisdictional income tax, foreign jurisdiction vat, gst compliance filings (4) risk management (5) coordinate tax planning, tax compliance, tax accounting, tax controversy (6) SEC reporting (7) regulatory/compliance. Schlegel earned a Doctor of Jurisprudence (J.D.), concentration in U.S. Domestic Federal Tax & International subsidiaries/affiliates/ joint ventures, U.S. taxation of foreign operations, Foreign taxation of U.S. companies Oil & Gas, Mining & Mineral Extraction. Legal & Tax Accounting: E&P, Working Interests, Gross Production Interests, Revenue Interests, Royalty Interests. M&A Equity "Carve-Outs" and Spin-Offs [I.R.C. 368]. U.S. Tax Exempt Organizations (EO) 26 U.S.C (IRC) * 501 (a), 501 (c) (3) Public Accountancy (B.Sc.), concentration in U.S. Domestic Federal Tax tax controversy administrative hearings & proceedings (APA) practice U.S. Government, Department of Treasury Southwest Regional Counsel, Major Case Appeals, enforcement/adjudicatory, Public Policy Analysis (B.Sc.), Penn State Institute for Policy Research & Evaluation (IPRE), applying hard skill sets in policy analysis. See Government Affairs Practice, Case Study No. 4, infra. p.16. Law firm government affairs & legislative affairs practice local, state, federal legislative drafts & committee submission, public policy research & analysis. Quick Review of Hard Skill Sets: U.S. Parent, Subsidiary Domestic Tax & Foreign Operations Tax Multistate Direct & Indirect Income Tax Filings Compliance South Dakota v. Wayfair Economic Nexus Standards Civil & Criminal Government Investigations Contested Tax Controversy Administrative Appeals 1934 SEC Act Anti-Fraud Provisions SEC Note Disclosures, FCPA Global Tax architecture practice Deloitte FP&A Strategy Practice KPI Analytical Practice Econometric Modeling Budgeting, Costing & Planning Due Diligence & Undertakings * Forensic Accounting & Criminal Auditing Cases * Preservation of Document Evidence & Custody Identification of other evidence, FRE 404 * Governance & Regulatory Compliance Review * Financial Statement Analysis * Government Relations & Affairs Legislative & Regulatory Advocacy * Federal & State Agency Hearings * Business Teaching Curriculum: Schlegel combines textbook lectures with case studies, federal & state judicial opinions, professional journal articles, major print media investigative pieces, classroom discussion. College Teaching Portfolio, Philosophy & Methodology, p. 22, infra., Business Law, Advanced Accounting & Federal Tax, Multi-jurisdiction Statutory Law of Business Organizations and Federal Pass-Through Tax Elections Compilation, Review of Financial Statements in accordance with AICPA member standards which conform to adopted FASB and GAAP principles. Instructional Practitioner (IP) or Practice Academic (PA) AACSB status. Mock Classroom Case Studies: Analyze and review statutes, regulations, judicial opinions. (1) Monitoring legislative, judicial & administrative developments (2) Draft and/or review memoranda supporting federal, state corporate income tax implications of proposed company business transactions or structural reorganizations (3) Review memoranda & tax accounting documenting federal, state corporate income tax filings (4) Analyze federal, state corporate income tax penalty assessments to determine accuracy and whether or not protest or appeal shall be recommended to the ExComm of the Board or the VP/COO (5) Preserve, organize, question preparers for depositions and witness lists, conceptualize flow charts in relation to evolution of documentary evidence to be admitted into administrative hearing audit, appeal, or docketed state district court trial proceedings (6) Review statistical modeling to study impacts of proposed federal, state corporate income tax legislative amendments and proposed legal entity organizational structural changes, e.g., IRC 368, on corporate tax reserves. Schlegel's specialized curriculum, FP&A hard skill sets, pp.19,20, are consistent with skills recommended by Deloitte for specialization in Financial Planning & Analysis (FP&A): (1) Strategic Planning derived statistical analysis of populated sets of financial data. (1) (a) Budgeting, (1) (b) Forecasting (2) Management Reporting: (2) (a) Revenue/ Expense Allocations, (2) (b) Performance Measurements, (2) (c) Distribution dissection of profitability centers (3) Decision Support & Controls: (3) (a) Accounting/ Federal Tax Policy, (3) (b) Internal Audit, (3) (c) Financial Analysis, (3) (d) Project Management (4) Specialized Expertise: (4) (a) Advanced U.S. Domestic Federal Tax Matters & International Business Transactions, (4) (b) M&A [IRC *368 Reorganizations], (4) (c) Risk Management, (4) (d) Emerging markets: North America, South America, EMEIA, APAC Regions. Tax Architecture Legal Opinion, Review of Federal Tax Elections Controlled Foreign Corporation (CFC) in each region or sovereign accessing PPP legislation/taxation incentives. See discussion, infra., on 01/01/2019 EU Anti-Tax Avoidance Directive (ATAD) and IRS proposed regulations under IRC *951A GILTI (2018) high-profitability / low fixed asset base ratio. Ecommerce & high-technology/ software development/sales firms. I have a significant background in statistical analysis, hard skill sets valued by the public sector in budgeting & forecasting. Three (3) years, Chief Compliance & Regulatory Affairs Officer, Chief Accounting Officer, see infra., pp. 6,13. Hard skill sets in public policy, Administrative Procedures Act (APA), proceedings & hearings before federal & state administrative agencies. License to Practice Law, Specialization in Federal Tax Law, provides superior practice rights to AICPA Member Practitioner: Firms appear to prefer licensing in two practice professions presenting both ethical conflicts in client representation and privilege protection of confidential communication. Incisive cross-examination can impair testimony of the holder of two professional licenses in law and as AICPA-member or CICA-member practitioner in preparation of client compliance returns for submission to a U.S. or Canadian government agency. A criminal prosecutor or government counsel may be able to reach incriminating, derogatory, embarrassing conversations, background query consult concurrent to preparation with company senior officer, or document evidence submission or offer of submission presenting factual matter to establish the return was prepared primarily within the experience and profession of a CPA. How items entered on the returns were arrived at and from which client source documents cannot be revealed as a client confidence by an attorney, but may be judicially ordered as a CPA without respect to Fifth Amendment privileges which are testimonial. A CPA may refuse discussion of preparation or entry of transactions or sources with assertion of the Fifth inuring solely to the CPA and not to a subpoena of the compliance or source documents. Client source documents used by attorney to prepare a return and in the custody of the attorney shall not be produced by subpoena unless a probable cause showing of the commission of a crime in which counsel is an accomplice. The tax expertise of an attorney specializing in federal and international taxation with an undergraduate degree in public accountancy presents superior versatility in representation venues, research, preparation of different forms of documentation, horizontal and vertical architecture of tax transactions and infrastructure, criminal tax statutory violations and procedure, civil government investigations. The second issue to address is the comparability of an advanced law degree (LL.M.) in tax and the combination of an undergraduate degree in public accountancy (B.Sc.) with emphasis in federal tax law, Juris Doctor (J.D.), supplemented with graduate tax work in Law and Business Administration. We look at a top program, Washington University in St.Louis School of Law LL.M. Tax Degree. Required: Federal Income Taxation (3) Federal Tax Code, Statutory Interpretation Federal Agency Deference (IRS) Kisor v. Wilke Electives (21 Hours) : Federal Taxation of Corporations (3) Federal Taxation of Partnerships (3) State and Local Taxation (3), Direct & Indirect Income Taxation South Dakota v. Wayfair Federal Tax Procedure (3), Administrative & Judicial procedures Federal Estate and Gift Taxation (3), "Gross Estate, " "Taxable Estate, " Estate Planning International Taxation (3), Examination of international distribution contracts Tax-Exempt Organizations (3), Organization, Qualification, Governance IRC *501 (a), *501 (c) (3) Accounting (3), Financial Statement analysis and disclosure Tax Research Writing (3), U.S. Tax Practice, Primary & Secondary tax resources Administrative and Judicial Tax precedent Supervised Research (3), Externship (3)

Highlights:

• SEC
• Securities and Exchange Commission (SEC)
• Accounting
• Audit
• Financial
• Securities
• Actor
• Banking Industry
• Bankruptcy
• Budgeting