| ERNEST F. AUD, JR. Partner, Ernst & Young LLP, Chicago, IL Ernest F. Aud, Jr. is an International Tax Partner and National Co-Chair of Ernst & Young’s Transfer Pricing practice. He has consulted multinational corporations in international tax transfer pricing issues for more than 20 years. His experience includes structuring corporate operations (outbound and inbound), utilization of foreign tax credits, foreign tax minimization, and various types of intercompany transactions including use of intangibles by affiliates. Mr. Aud key corporate experience: responsible for the development and implementation of medical products company’s strategy towards IRS examinations of Puerto Rican operations resulting in the settlement at the agent level. The settlement provided a sound basis for sustaining profits I Puerto Rico after enactment of Section 936(h). Other key experience includes Section 482 Planning, Advance Pricing Agreements, Section 482 IRS Audit Defense, and International Corporate Tax Planning. Mr. Aud is a frequent speaker for various organizations and a contributor to numerous professional journals including Tax Management Journal, International Tax Journal and BNA Tax Management Portfolio (Co-author of section 936 portfolio). Mr. Aud received his JD at Indiana University, his BBA in Accounting at University of Notre Dame, and his CPA in Illinois and Indiana. |