Mandana Malone

Experience

1. Managing Director

   Deloitte

   Jul 2004 — Present · San Francisco, CA, US

   Advise multinational corporations on the U.S. tax consequences of their cross-border transactions and global operations (e.g, intellectual property migrations, legal entity structuring, financing and mergers and acquisitions transactions). • Lead and manage large scale mergers and acquisitions projects – recently advised on the largest leveraged buy-out (“LBO”) since the 2007 financial crisis and one of the ten largest LBOs of all time. • Advise clients within the e-commerce industry on the specific international tax issues relevant to their business such as the sourcing and characterization of their income, Subpart F income and U.S. permanent establishment/effectively connected income issues relevant to server location. • Research and draft opinion letters and memoranda analyzing international tax issues including permanent establishments, Subpart F income, FIRPTA transfers and tax implications associated with corporate restructurings. • Managed $1 billion debt repayment transaction with associated tax implications across three jurisdictions. • Review and provide advice to clients on their international corporate tax filings.

Education

• Washington University in St. Louis School of Law

  Doctor of Law (J.D.)

• Saint Louis University

  Bachelor of Science (B.S.)

Skills

• Tax Law
• Financial Structuring
• Tax Advisory
• Farsi
• Corporate Tax
• International Tax
• Restructuring
• Tax Treaties
• Tax Accounting
• Fin 48
• Cross-Border Transactions
• French
• Mergers
• Vat
• Tax Research
• International Tax Consulting
• Tax
• Due Diligence
• Partnership Taxation
• Income Tax
• M&a Tax
• Big 4