Brian Gryder

About Brian Gryder

In high school, I spent afternoons immersed in musty Tax Reporters on the third floor of…

Experience

1. Director, International Tax

   Morris D\'angelo -- Not Just Another Cpa Firm

   Dec 2016 — Present · San Jose, CA, US

   On Disability leave until estimated return on Dec-2025Implement tax-saving strategies through effective collaboration, leadership, and supervision, achieving significant financial results for businesses, individuals, and trusts.• Lead restructuring of 29 business entities post-Tax Cuts and Jobs Act (TCJA), saving $3M and minimizing Global Intangible Low-Taxed Income (GILTI) through team-based modeling and careful IRS guidance monitoring.• Collaborate across departments to save $30M tax, developed a tax-free Controlled Foreign Corporation (CFC) sales strategy using IRC §1248 and §245A.• Supervise employee expatriate tax adjustments, working closely with HR teams to optimize pay adjustments.• Manage the filing of final Internal Revenue Service (IRS) Form 3520 for Intentionally Defective Grantor Trust (IDGT) while overseeing a multi-year exit strategy.• Lead multi-year planning to minimize U.S. assets for expatriated visa holders and their resident spouses.Transition Toll Tax (IRC §965):• Collaborate with stakeholder advisors to save $1.9M by rebuilding 20 years of Earnings and Profits (E&P), identifying inheritance and buyout adjustments.• Spearhead efforts to reduce foreign E&P by $750k through team-based analysis of bad debts.Transfer Pricing:• Manage transfer pricing adjustments to minimize GILTI inclusions.• Lead functional analysis for a Research & Development (R&D) cost-plus strategy.Penalty Reduction:• Partner with legal teams to prepare IRS Form 14457 to reduce Foreign Bank Account Report (FBAR) penalties from $1.2M to $50k.• Manage abatement of penalties on late-filed international forms.

Education

• Samford University

  Bachelor of Science, cum laude, Accounting

• Samford University

  Juris Doctor, Business Law

• Harvard Extension School

  Graduate Certificate, Business/Corporate Communications

Skills

• International Tax
• Income Tax
• Tax Research
• Transfer Pricing
• Accounting for Income Tax
• Consolidated Returns
• Acquisition Due Diligence
• Project Planning
• Project Management
• Process Optimization
• Intercompany Agreement Management
• Transfer Pricing Studies
• Tax
• Corporate Tax
• Financial Reporting
• Cpa
• Foreign Tax Credit
• Finance
• Management
• Sarbanes-Oxley Act
• Mergers & Acquisitions
• Legal Research
• Fas 5
• Restructuring
• Financial Planners
• Tax Returns
• Us Gaap
• Due Diligence
• Contract Negotiation
• Sec Filings
• Tax Accounting
• Budgets
• Corporate Law
• Tax Reporting
• Analysis
• General Ledger
• Employee Benefits
• Accounting
• Leadership
• Big 4