Darryl Delmonico

About Darryl Delmonico

Seasoned executive tax professional with over 25 years of Big 4 and multinational/industry corporate tax department experience, specializing in Subchapter C issues, cloud computing/software-as-a-service issues, mergers & acquisitions, internal restructurings, managing/leading/resolving tax examination controversies, and domestic income tax compliance and reporting. Previously, I led the following corporate tax functions at salesforce.com: • Domestic and cross-border planning and structuring activity • Mergers, acquisitions, structuring, and restructuring tax activities • Domestic income tax and employment/payroll tax examinations, analysis, and resolutions (with a focus on research and development credit, transfer pricing, and complex planning issues); collaborated on foreign withholding and income tax matters • Domestic income and non-income tax analysis, assessment, quantification, and reporting (e.g, FIN 48 and FAS 5 exposure analysis and documentation) • Benefits-in-Kind taxation, planning, and reporting/compliance • Tax planning for all corporate venture capital investments and dispositions • Ad hoc tax planning (e.g, Section 1031 “like-kind-exchange” planning, Affordable Care Act analysis, corporate foundation issues, etc.) • Domestic income and non-income tax incentives, grants, and credits (refundable and otherwise) • Cross-functional internal tax liaison for the following corporate groups:** Corporate Legal (domestic tax lead for all contract review, including real estate, convertible and non-convertible financing agreements, legal settlements, severances and employee issues, customer contracts, acquisition agreements, investment agreements, etc.)** SEC reporting and Technical Accounting** Global equity program (i.e, stock-based employee compensation)** Corporate Payroll taxation ** Corporate Development and Salesforce Ventures investments Significant familiarity with all international tax matters (e.g, income characterization, withholding taxes, foreign tax planning, etc.) and Subchapter K expertise.

Experience

1. Mergers & Acquisitions Tax Director

   Snowflake

   Jul 2023 — Present · San Francisco, CA, US

Education

• Pennsylvania State University

  Bachelor of Science

  1986 — 1990

• University of California, College of the Law, San Francisco (formerly UC Hastings)

  JD

  1993 — 1996