Director of Tax - International, M&A, IRS Audit @ From March 2015 to Present (10 months) Director - International Tax @ From December 2013 to Present (2 years 1 month) Senior Manager - International Tax @ From February 2013 to November 2013 (10 months) Senior Manager - Tax - M&A and Audits @ Lead the M&A tax function. Conduct due diligence and develop structuring options for domestic and foreign targets in order to mitigate potential tax risk. Direct all federal and international tax IRS audit activities. First point-of-contact with IRS. Coordinate IDR responses, develop defense strategies, negotiate and resolve contested issues. Manage all company uncertain tax positions (FIN 48) and the quantification of potential audit settlements from a cash and financial statement perspective. Developed favorable settlement agreement with IRS Appeals officers regarding $400 million contested issue during 1998-03 audit cycle. Led Appeals meetings and coordinated outside council. Responsible for the development of the five year long range business plan from a tax perspective, including effective tax rate and cash tax rate calculations. From May 2010 to January 2013 (2 years 9 months) Project Manager - Domestic Tax @ Coordinated all corporate Federal M-3 adjustments and proforma 1120 tax returns. Supervised 10-person research and development tax credit team which annually increases company cash flow in excess of $150 million. Managed captive insurance companies, including analyzing tax planning opportunities to maximize potential tax benefits. Directed the implementation of the domestic manufacturing tax deduction processes resulting in annual savings in excess of $30 million. Sought input from business units and accounting functions in the development of calculation and information gathering processes. From January 2008 to May 2010 (2 years 5 months) Project Manager - International Tax @ Project Manager - International Tax International FAS 109 manager responsible for quarterly tax processes and international component of the long range business plan. Established FIN 48 positions for international issues. Point-of-contact with external auditors. Analyzed business decisions to quantify potential Subpart F, foreign tax credit, PE, withholding tax, and transfer pricing ramifications. Coordinated foreign tax compliance for European operations utilizing 3rd party consultants. Managed income tax and VAT issues of foreign operations, including foreign audits. Led internal resources and third party consultants on FSC/ETI compliance resulting in annual tax savings of over $200 million for the company. Determined project goals, timelines, and allocated responsibilities to team members. From September 2005 to January 2008 (2 years 5 months) Senior Associate - International Tax Services @ Served numerous Fortune 500 companies on both inbound and outbound international tax issues including: Subpart F, PE, VAT, IP migration, withholding tax, FIRPTA, transfer pricing, tax treaties. From July 2000 to September 2005 (5 years 3 months) Senior Associate, Associate - Japanese Business Group @ Japanese Business Group Led tax compliance and consulting engagements for "inbound" clients (U.S. subsidiaries of Japanese parent corporations). Prepared federal (Form 1120), state, and international (Form 1042, 1120F) tax returns. From July 2000 to September 2005 (5 years 3 months)

MBA, Finance, General @ Northwestern University - Kellogg School of Management From 2007 to 2009 Bachelors, Finance, Accounting @ Miami University From 1996 to 2000 Dave Wehrle is skilled in: Federal Tax, International Tax, Tax Accounting, Corporate Tax, Accounting, Transfer Pricing, Due Diligence, Income Tax, Auditing, Internal Audit, Tax Returns, VAT, FIN 48, Sarbanes-Oxley Act, Tax, US GAAP