 |
 |
 |
 |
 |
 |
 |
Understanding Form 5471 & Owning Foreign Corporations
LIVE Webcast
John Dillinger
(Former IRS Agent)
John Dillinger, CPA, MS(Tax)
John has provided tax services for over twenty-five years. During that time he has provided high quality personalized service to a wide variety of clients ranging from individuals to small and medium sized companies in a variety of diverse industries. John’s background in tax preparation, public accounting and as an IRS Auditor gives him a unique perspective into your tax needs.
Previously, John focused on the IRS Offshore Voluntary Disclosure Program. Currently, he continues to help clients come into compliance with their IRS foreign reporting requirements with the IRS and is preparing for the recently passed FATCA provisions of the HIRE Act in regards to future international filing requirements.
John is licensed as a Certified Public Accountant. He earned his Masters Degree in Taxation from Golden Gate University and a Masters Degree in Accounting and Financial Management from Keller Graduate School of Management. He also holds a Bachelor of Science degree from Washington State University.
Prior to starting his own CPA firm, he gained experience in International Tax at the "Big Four" accounting firm, PricewaterhouseCoopers and as an Internal Revenue Agent with the Self-Employed/Small Business Division of the Internal Revenue Service.
John recently gave presentations on the US Tax Requirements when Buying Property Overseas at "International Living’s - International Real Estate Investment Forum" in Toronto, Canada and in Las Vegas, Nevada.
Additionally, John's publishes a blog on the IRS filing requirements for U.S. persons with foreign entities, Fideicomiso.wordpress.com and published articles on the subject with The Guadalajara Reporter, The Banderas News and The Pacific Pearl.
Dillinger, CPA was established to serve the tax, and consulting needs of individuals, small businesses and international entities in the San Francisco area and across the country.
Memberships
- AICPA
- California State Society of CPAs
Timothy J. Leska
Attorney at Law
Pepper Hamilton LLP
Timothy J. Leska is an associate with Pepper Hamilton LLP, resident in
the Philadelphia office. Mr. Leska focuses his practice on general tax
matters.
Prior to joining Pepper, Mr. Leska was an attorney in the Office of Chief
Counsel for the Internal Revenue Service in Washington, DC. While at
the IRS, Mr. Leska participated in the issuance of IRS pronouncements,
including final regulations regarding partnership allocations of creditable
foreign tax expenditures.
Mr. Leska earned a B.A., magna cum laude, in political science and
philosophy from Lycoming College in 2001, and a J.D., cum laude, from
Temple University School of Law in 2004. At Temple, he was a member
of the Temple Law Review and received a graduation award for outstanding
achievement in taxation. Mr. Leska also earned his LL.M. (taxation),
with distinction, from the Georgetown University Law Center in 2007.
Mr. Leska is admitted to practice in Pennsylvania.
William P. Elliott, CPA, J.D., LL.M.
Partner and Firm Director of International Tax
Cherry, Bekaert & Holland, L.L.P.
Bill is a Certified Public Accountant and international tax lawyer with more than 25 years of diversified tax planning and compliance experience. As the Firm Director of International Tax, Bill directs the specialized services and worldwide resources of the Firm to meet the international tax needs of clients firm-wide.
Based in the Firm’s Washington office, Bill provides clients with a full range of international tax and accounting services, including international and offshore taxation and planning, wealth preservation and asset protection, domestic taxation, management and business consulting, and litigation and legal advisory services.
Bill specializes in providing strategic planning and advisory services to assist clients across a wide array of industries with inbound and outbound entity transactions, foreign and domestic estate and income tax planning, transfer pricing, intangible and intellectual property valuation, asset protection planning, captive insurance arrangements, expatriate taxation, offshore e-commerce planning, and corporate and pass-through entity taxation and consulting.
Widely recognized for his expertise in tax matters, Bill writes and edits extensively for CCH’s TAXES - The Tax Magazine® as well as CCH’s S corporation publications, The Journal of International Taxation, Tax Notes International, and other leading domestic and international tax journals and publications. He has also developed international tax CPE programs, and speaks frequently at leading tax and international tax programs directed to practitioners as well as individuals and companies.
Prior to joining CB&H, Bill served as the managing international tax partner for Mahoney Cohen and Company in New York City, and previously served as a managing member of DECOSIMO Global, headquartered in Cincinnati and Grand Cayman. He has extensive experience serving clients across several industries, including the manufacturing, distribution, insurance, retail, financial, transportation, not-for-profit, telecommunications, media and franchisee sectors.
Bill graduated with honors from Millsaps College, where he received his Bachelor of Business Administration in Accounting degree. He received his Juris Doctor from the Concord Law School, and graduated summa cum laude with a Master of Law degree (LLM) in International Taxation from St. Thomas University School of Law.
Licensed to practice as a CPA in Alabama, Kentucky, Mississippi, New York, Tennessee and Virginia, Bill is a member of the American Institute of Certified Public Accountants (AICPA); the Tennessee, Georgia, and Mississippi Societies of CPAs; the International Tax Planning Association (ITPA); and the International Fiscal Association (IFA). In addition, Bill is a credentialed business valuation and appraisal professional, holding the ABV (Accredited in Business Valuation) and the CVA (Certified Valuation Analyst) designations.
David B. Joranko
National Director
International Tax Compliance & Quantitative Consulting Services
Ernst & Young LLP
Dave is a Partner and National Director of International Tax Compliance and Quantitative Consulting Services for Ernst & Young LLP. Based in Cleveland, Dave has over 25 years of experience assisting U.S. multinational businesses with U.S. tax planning and reporting related to their international operations. Dave’s areas of focus include the U.S. foreign tax credit, U.S. export tax incentives (IC-DISC, FSC and ETI), controlled foreign corporation and foreign branch calculations and international mergers and acquisitions. Dave has also assisted clients in determining their U.S. Production Activities Deduction under Section 199.
Dave has been a frequent speaker for the Council for International Tax Education, ATLAS, the Tax Executives Institute, and the FSC/DISC Tax Association. He authored the July 15, 1996 Tax Notes International article “A FSCful of Dollars: Maximizing FSC Benefits through Transaction Level Pricing” and the November 27, 2000 TNI article on the FSC Repeal and Extraterritorial Income Exclusion Act of 2000.
- B.A., Business Administration, Duke University
- J.D., Ohio State University College of Law
- CPA in Ohio, Illinois, New York and Georgia
- Admitted to the Ohio Bar
Understanding Form 5471 & Owning Foreign Corporations
Speaker Firms:
Pepper Hamilton LLP
Cherry, Bekaert & Holland, L.L.P
Ernst & Young LLP
Upcoming events.