Snapshot and Years of Experience

Grace Chen has over 20 years of Federal, state, and international tax compliance, tax accounting, tax consulting, tax controversies, transfer pricing, and project management experience. She has practiced at large, multinational corporations and public accounting firms.

Tax Compliance

• Review and prepare federal and state corporate income tax returns, including analysis of consolidated net operating losses, §382 and SRLY rules, and §163(j) limitation of interest deductions.
• Review and prepare partnership returns.
• Review and prepare GILTI, FDII, and BEAT calculations, Section 956 inclusion, Subpart F and §78 gross-up calculations, including high-tax elections and look-through rules, §904 foreign tax credit limitation, E&P computations, Forms 1118, 5471, 5472, 8858, 8865, and 8883, including disclosure requirements and asset allocations for §338 elections.
• Review and prepare Form 8975, Country-by-Country Reporting (“CbCR”) requirements.

Tax Accounting

• Review and prepare domestic and foreign income tax provisions under US GAAP, including tax footnotes and disclosures
• Analyze interim effective tax rate, identify significant discrete and/or reconciling items, and reconcile balance sheet tax accounts
• Evaluate need for valuation allowances
• Review and compute reserves for tax uncertainties
• Review and prepare opening balance sheet of newly acquired foreign entities for US multinational companies
• Assist foreign controllers with the preparation of foreign income tax provision for US GAAP
  purposes

Tax Consulting

• Perform US tax and tax accounting due diligence and pre-acquisition and post-acquisition restructuring projects for Global multinational companies
• Perform stock and asset basis study to support 338(h)(10) opportunity
• Assist HR team to manage potential tax and permanent establishment exposures related to employee’s teleworking requests
• Perform research and provide advice on cross border transactions, providing pros and cons, recommendations, conclusions, and next step(s) from the US tax perspectives
• Evaluate withholding tax and required documentation of Forms W-8 series
• Analyze state nexus post Wayfair

Tax Controversies

• Prepare and review responses of IRS IDRs
• Prepare and review responses of State IDRs

Tax Reform & Transfer Pricing Developments

• Closely monitor the ever changing developments of income tax law
• Closely monitor state developments after Wayfair
• Closely monitor BEPS 2.0

Project Management

• Manage R&D credit projects
• Manage Transfer Pricing projects, including preparation of Master File
• Manage domestic and international restructuring projects
• Manage global tax function effectiveness projects: tax control and risk management
• Manage basis of fund investments