Snapshot and Years of Experience

Holly Welborn has over 35 years of Federal and international tax compliance, tax accounting, transfer pricing, audit defense, and project management experience in both industry and public accounting. Holly has worked as an International Tax Director for more than 18 years and was most recently a Tax Director of a $10 billion global consumer products company.

Tax Leadership

• Management and direction of all aspects of tax compliance, transfer pricing, tax accounting, and audit defense for federal and international tax

Tax Compliance

• Federal and international tax compliance 
• Preparation and review of earnings and profits, subpart F income, section 956, GILTI, BEAT, FDII,  tested income/loss, foreign tax credits and country-by-country reporting
• Preparation and review of Forms 965, 1065, 1118, 1120, 5471, 5472, 5713, 8865, 8975, 8990, 8991, 8992, and 8993
• Review of Canadian income tax and nonresident tax returns, including providing detailed support for preparation of the returns
• Preparation and review of U.S. Federal and Canadian Federal and provincial estimated tax payments

Tax Planning / Transfer Pricing

• Development and review of repatriation plans 
• Review and evaluation of permanent establishment risks and remediation plans
• Legal entity rationalization and post-acquisition integration planning
• Management of global transfer pricing requirements, including adherence to global transfer pricing policies, preparation and review of Master File and Local Files, quarterly review of intercompany profitability, and maintenance and preparation of intercompany agreements

Tax Accounting

• Review of domestic and foreign income tax provisions
• Preparation and review of Canadian income tax provisions
• Provision to return analysis and preparation of deferred proofs
• Analysis and proof of current taxes payable
• Preparation of quarterly GILTI, FDII, and FTC calculations, withholding tax analysis,  and valuation allowance analysis

Federal and Local Country Tax Audits

• Management of IDR process related to U.S. international tax matters
• Lead Canadian tax controversy matters, including management of multi-year income and nonresident withholding tax audits
• Active participation in foreign income tax audits
• Evaluation and negotiation of settlement options
• Hold a Canada Revenue Agency non-resident representative number