Office of Charles Stake Tax Law, LLC

Business and Legal Advisory

Tax Attorney for Domestic and International Tax Issues with over 25 years of in-house tax & business experience at KPMG, Global Crossing, GE, Amazon and Nike.State of Oregon Diversity and Inclusion certified minority business enterprise (MBE) and emerging small business (ESB). Certification number 13811.

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About

Charles Stake has spent more than 25 years as an in-house international tax lawyer at some of the largest and most recognizable multinational companies in the world.At Global Crossing, Mr. Stake led the tax function and held senior tax counsel roles at General Electric, Amazon and Nike.Mr. Stake focused on US and non-US local country tax policy, controversy and planning. He has dealt with government officials from every continent including the European Commission and the IRS.These experiences shape Mr. Stake's approach to every case with the goal of achieving the best possible and practical solution to complex tax matters.

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Practice Areas

Tax Planning
-US domestic, international and cross border
-Local country domestic and cross border, e.g., China, Singapore, Mexico, Netherlands, Germany, UKTax Controversy Prevention and Defense
-Audit readiness and audit defense
-Competent authority, Mutual Agreement Procedure (MAP), and Advance Pricing Agreements (APA)Tax Policy
-OECD Pillar 1 and Pillar 2
-BEPS
-Tax Reform

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Experiences

PLANNING
-Led $11B international restructuring in conjunction with a spin-off. Organized employees, operations and assets into business silos and subdivided them by country (UK, Germany, US, Canada, Japan, Singapore, Brasil and Mexico). Did this structuring with less than $100K total cost impact for VAT, income and transfer taxes.
-Secured $2 billion worth of Customer Financing Programs. Led tax structuring for five different types of financing programs to help customers and distributors in emerging markets (ASEAN, Africa, and LATAM) purchase equipment. Programs in place with USAid, Citibank, OPIC, EXIM and PEFCO for structured products (loans, guarantees, swaps, sales of loans).
-Developed a tax-free plan that eliminated more than $40B of domestic and international intercompany balances. This involved more than 150 legal entities in 28 different countries. Plan was complicated by two facts: (1) only 80 legal entities filed for Chapter 11 relief; and (2) those entities filed only in the United States (jurisdictional issues and ramifications varied by country).
-Tax lead for listing on NASDAQ and bond issuances. Developed forecast models, repatriation strategies, and roadshow packages, e.g., Credit Suisse and Goldman for $500M high yield bond offering; Goldman for $350M bond issuance out of Bermuda followed by an interest rate swap out of the US; ABN for $100M of add on bonds; Credit-Suisse for a $225M 144A for life issuance.CONTROVERSY
-Had a $140 million Canadian Revenue Authority assessment rescinded via competent authority process with Canada, the United States, the Netherlands and Singapore. This required clear explanations of the detailed tax technical and benefits to officials from each country.
-Managed over 120 ongoing tax controversies at audit through to litigation at Supreme Court level across 55 countries.POLICY
-Negotiated in country incentives totaling more than $2 billion annually.

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