CORPORATE / TAX COUNSEL
Posted on: 2011-11-10
MARSHA-LAINE F. DUNGOG, ESQ. (213) 880-8844
Santa Monica, CA 90404 / Alexandria, VA 22301 [email protected]
CORPORATE / TAX COUNSEL
Capital Funding & Expansion / Global M&As / Complex Transactions / Negotiations / Finance / JVs / IP Strategic Partnerships / Litigation / Debt Restructuring / Contracts / Risk Management / Licensing / Treasury
A versatile and dynamic attorney, I offer more than 12 years of state, federal and international tax/general legal experience. I have been a consistent strong contributor adding considerable value to major companies (Dow Chemical) and global consulting firms (KPMG) as well as with both large/smaller law firms. My key skills include:
Effectively resolving tough tax, business and legal problems Achieving optimal results in global contract negotiations
Applying strategic perspective to ensure superior long-term results
Motivating and leading teams to meet or exceed annual objectives
Prior to my Master of Laws in Taxation from Georgetown University and JD from Golden Gate University, I earned a BA in Political Science from University of the Philippines. Member, California/Michigan State Bar Associations and FINRA Arbitrator. Admitted to practice before US Tax Court and US Supreme Court.
Distinctive Accomplishments
Helped Fortune 500 company save millions of dollars in taxes. Dow Chemical incurred multi-million dollar tax hits for consecutive years. Spearheaded Tax/Treasury team, gaining a more comprehensive tax and risk picture. Developed innovative treasury hedging documentation procedures, saving $20M in taxes per year.
Oversaw rapid resolution of major tax liability issue. Dow needed a strategy for overcoming negative impact of global interest rate decline on maturing multi-billion dollar cross currency swaps. Led cross-functional team, mitigating tax/financial accounting impact of proposed swaps to save millions/avoid impact on earnings per share.
Played key role in settlement of tax liability cases. Dow faced an unresolved federal tax deficiency of $162M from previous R&D activities. Added key staff resources to manage litigation and streamline in-house discovery. Eliminated at least $2M in outside counsel fees/costs. Cases eventually settled, saving millions more.
Set precedent to save client millions. Pillsbury Winthrop client, Hughes Electronics, faced property tax liabilities on its artificial satellites. Contested assessments using international law/federal tax principles. Persuaded CA Board of Equalization to reject assessments, saving Hughes $millions. Precedent was adopted into Property Tax Rule.
Developed innovative solution to help national online retailer avoid significant tax penalties. A major online retailer/Pillsbury Winthrop client, faced millions of dollars in state penalties and audit costs due to new state laws impacting unused gift certificates. Created a uniform gift certificate compliance program, applicable across client’s 100+ US stores. In addition to state fees/audit cost savings, averted hundreds of costly man-hours per year.
Career History
Consulting Tax Attorney, 2011 to Present. Launched tax, risk management and litigation advisory practice.
Tax Partner, Hobson Dungog Davis LLP, 2009 to 2011. Managed 3-4 attorneys, providing tax advice and representation to high net worth individuals, entrepreneurs/startups, film funds and movie production companies.
Senior Corporate Counsel, Liner Grode Stein Yankelevitz Regenstreif & Taylor LLP (LGS), 2007 to 2009. Oversaw 10 attorneys/staff, furnishing tax structures for film financing, M&As, dispositions and hedge funds. Also assisted with tax audits and representation for high net worth clients.
Tax Counsel, Dow Chemical, 2004 to 2007. Oversaw global CPA/global tax team of 50±, serving as primary tax liaison and interface with Treasury and business units. Provided legal support for tax audits and managed outside litigation counsel. Teamed with business, legal and finance units to marshal effective tax rates and maintain global tax transfer pricing structures/policies.
Tax Associate, Pillsbury Winthrop LLP, 2000 to 2004. Recruited by $300M+ firm to furnish legal research, writing and due diligence support for complex federal and state litigation as well as transactional matters.
Senior Tax Associate, KPMG, 1999 to 2000. Managed staff of four, supporting National Office tax products and drafting technical tax white papers. Also developed in-house training modules on emergent tax issues.
Earlier, served as Law Clerk with US Tax Court and Extern with the US Bankruptcy Court.