Kevin Cunningham

About Kevin Cunningham

I provide a broad range of international taxation services to multinational corporations…

Experience

1. Managing Director

   KPMG US

   Mar 2006 — Present · DC, US

   I practice in all areas of international taxation with an emphasis on U.S. multinational tax planning. I also have represented clients in audits and appeals before the Internal Revenue Service. Some of my recent engagements include the following:(1) I prepared detailed recommendations to restructure the operations of a number of large businesses including (i) an offshore drilling contractor into two separate businesses and (ii) a manufacturing company. After the recommendations were accepted by upper management, I had a leading role in implementing the plans. In that capacity, I advised these companies and their attorneys in connection with a variety of legal implementation issues. As part of the restructurings, I consulted with the companies on issues such as (i) tax-efficient financing,(ii) choice of holding company local thin-cap and distributable reserve planning,(iv) the impact of U.S. international tax reform on the companies, and (v) U.S. foreign tax credit planning.(2) I advised on the restructuring of over $1 billion in sales of a leading manufacturing company as part of an effort to increase commercial and tax efficiency throughout the planning, procurement, manufacturing and distribution processes. Established a tax-efficient principal company in connection with the business transformation process. Reviewed the impact of the restructuring on existing intellectual property arrangements and provided advice to coordinate the restructuring with those arrangements. I have written a number of articles and spoken on a variety of international tax subjects. I have authored articles in Tax Notes International and elsewhere on cross-border financing transactions, the new Section 385 regulations, and the worthless stock deduction. I regularly speak at Bloomberg tax seminars and recently provided the international tax update at the annual TEI meeting in upstate New York.

Education

• University of Virginia

  Doctor of Law (J.D.), Tax Law/Taxation

  1992 — 1995

• Georgetown University

  Bachelor's degree, Accounting

  1985 — 1989

• Georgetown University

  Master of Laws (LL.M.), Taxation

  1997 — 2001

Skills

• Operations Management
• Financial Modeling
• Corporate Finance
• Corporate Tax
• External Audit
• Gaap
• Business Development
• Corporate Tax Planning
• Cross-Border Transactions
• Business Valuation
• Cross-Border M
• Due Diligence
• Tax
• Internal Controls
• Us Tax
• International Tax
• Big 4
• Accounting
• Mergers & Acquisitions