TAX 655 Milestone Two Guidelines and Rubric You will s.docx
Resume 9_1_15
1. BRUCE D. JORLANDO
bjorland60@gmail.com
7715 Heathrow Lane Home: 419-824-0331
Spring, Texas 77379 Cell: 419-215-7770
CAREER SUMMARY
Results driven and proactive Director with over twenty-five years of extensive international and federal tax
experience with Fortune 500 manufacturers. Technical skills include strategic global tax planning, M&A,
transfer pricing and supply chain restructuring, local country tax planning, cash repatriation, US and local
tax audits, foreign tax credits, and US tax reporting. People skills include direct supervision of in-house
staff and Big Four loan staff, senior management presentations, partnering with Business Units, IRS and
local tax audit negotiations, and acting as Project Lead for cross-functional reorganizations.
WORK EXPERIENCE
SCHLUMBERGER LIMITED March 2016 - present
On April 1, 2016 Cameron International Corporation was acquired by Schlumberger Limited. My previous
responsibilities under Cameron continue under Schlumberger, with my primary focus being design and
implementation of tax efficient supply chain structure. Additional items with Schlumberger include legal
entity tax restructuring, post-acquisition foreign tax credit planning, cash repatriation, and BEPS transfer
pricing integration and compliance.
CAMERON INTERNATIONAL CORPORATION, Houston, Texas Oct 2010 – March 2016
Tier one oilfield service industry heavy manufacturer with sales of $8bb, operating in over 40 countries. .
Director, International Tax
Interim reporting to Chief Financial Officer. Key responsibilities include managing all aspects of US
international tax planning & compliance, foreign tax credit (FTC) & effective rate planning, global
transfer pricing planning & documentation for Equipment Sales, Intellectual Property (i.e.
Manufacturing Technology, ERP, and Trademark), and Services, tax lead for global supply chain
efficiency project, manage international tax issues of US federal exam & local transfer pricing exams,
global cash repatriation planning, FATCA & FBAR, and supervision of in-house staff, consisting of
two Senior Tax Managers, a Manager, and two Analysts. Cameron’s annual effective tax rate
consistently runs in the low twenty percent. Majority of time spend with Operations, non-tax Corporate
Functions, and outside advisors.
• Manage and enhance high-taxed FTC strategy that annually provides a 3% - 6% ETR reduction.
• Amended 2007 – 2009 Forms 1120 / 1118 to utilize roughly $30M of excess FTC’s and
successfully defended at Federal Exam.
• Cost Sharing Arrangement US/Ireland for Manufacturing Technology
• PCT & Cost Sharing Arrangement US/Ireland for ERP System
• Re-engineered IC Equipment Sales Transfer Pricing – Distributor Lead Model $2BB Sales
• Re-engineered §482-9 IC Service Charges – US, Singapore, Romania, and UK Hubs
• Project/Tax Lead for Centralized Supply Chain Buy/Sell Principal Structure
• Annual cash repatriation strategy - $100M - $500M
DANA HOLDING CORPORATION, Toledo, OH 1997 – 2010
Tier one automotive parts manufacturer with sales of $6bb, operating in 30 countries.
Director, International Tax 2007 – 2010
Reported to VP of Tax. Managing all aspects of US international and local country tax planning, US
compliance, and audits, and supervision of in-house Manager, Senior, and Big Four loan staff.
2. BRUCE D. JORLANDO Page 2
• Worked with Treasury and Legal Departments to develop and implement annual repatriation plan,
including dividends, returns of capital, I / C loans, advance payments, hybrid debt / equity
instruments (Luxembourg CPEC’s). Annual repatriation ranging from $150mm- $400mm.
• Project leader of cross-functional team to covert seven Mexican traditional manufacturers to
Maquiladora status. Migration of $30mm of taxable income to the US.
• Co-Project leader for Strategic Assessment of European Swiss Principle with toll manufacturing
and direct sales, in nine countries with $1.5bb sales. Developed tax and IP migration model,
assisted VAT, local PE, and US substantial contribution review. Annual tax savings $20mm.
• Acted as tax lead for $500mm global divestiture in six countries, provided local country tax and
repatriation planning, purchase price allocation, and negotiation with buyer.
• Established Swiss Global Hedging Center. Provided Section 475 Dealer review, framework for
hedging service agreement and provided local country tax and exchange control review.
• Worked with Corporate Treasury to develop and implement a Pan-European Cash Concentration
Cash Pooling Structure headquartered in Switzerland.
• Performed extensive foreign tax credit (FTC) planning and utilization, including negotiations and
Appeals reruns with the IRS. Annual FTC utilization ranging from $20mm - $200mm.
• US Tax Accounting for APB23 (pre & post Chapter 11), identify and develop FIN48 reserves for
transfer pricing and other issues, and identify deferred tax assets (NOL’s and capital losses) and
the application of valuation allowances (timing and release).
Manager, International Tax 1997 – 2007
• Provided tax counsel for Italian JV with European Partner. Legal and transactional structure
review, IP, and contribution negotiations with partner. Utilized Italian Consortium Tax Relief.
• Member of the Corporate Talent Management Committee that provided comments and
recommendations to senior management to identify, evaluate, and develop in-house staff.
• Provided tax planning and compliance for international portion of $1.1bb divestiture of Global
Aftermarket Unit, including purchase price allocation for fifteen jurisdictions, seller due diligence,
pre - sale restructuring, repatriation, and gain / loss calculations.
• Provided tax counsel for $400mm European acquisition; including legal entity structure, US
purchase of intellectual property and license back, and contract R&D. $1.5mm annual savings.
• Developed global intangibles strategy to centralize U.S. ownership of global R&D platforms for
immediate and or deferred licensing back to foreign operations. Identified and executed 40
license agreements, annually generating $40mm of royalties with $3.5mm tax savings.
• Drafted and implemented annual global transfer pricing process to provide required
documentation and transactional pricing for $900mm product sales, in over 20 countries.
• Created US SG&A Service Agreement and allocation process to charge $40mm annually to
foreign locations – tax documentation, local audit defense and FIN48 determination.
• Negotiated a reduction in multi-year IRS 5701 regarding Puerto Rico 936 transfer pricing, from
$127mm down to $16mm.
• Determined legal structure and type of sale by jurisdiction for $300mm US, European and Asian
divestiture. Assisted in purchase price allocation. Ten jurisdictions.
• Utilized “check the box” to Partnership status to trigger $130mm capital loss in French Holding
Company. Executed similar transaction in Argentina generating an $80mm capital loss.
• Used “check the box” hybrids to create Canadian debt pushdown of $175mm through the transfer
of German Subsidiaries. Double dip, $3mm annual savings.
WHIRLPOOL CORPORATION, Benton Harbor, MI 1996 – 1997
Consumer products manufacturer with sales of $8.5bb, and operations in 30 countries.
Manager, International Tax
All US International tax compliance and planning. 75 controlled foreign corporations, foreign branch
operations, foreign partnerships, foreign sales corporation, and numerous joint ventures and hybrid
entities. Served as Tax representative on cross - functional projects, mergers and acquisitions,
3. BRUCE D. JORLANDO Page 3
transfer pricing, regional tax planning and special projects. Supervised three international tax
accountants.
• Implemented Global R&D Funding and manufacturing intangible license back agreements, that
generated low taxed, foreign source royalty income and $13mm FTC Limitation.
• Provided tax planning for Brazil and Argentina. Coordinated and lead semi-annual tax planning
conference with Brazilian J.V. partner, to reduce local country tax and FTC’s.
DOW CHEMICAL COMPANY, Midland, MI 1990 – 1995
Chemical manufacturer with sales of $20bb, and operations in 70 countries.
Counselor International Tax – Dow Chemical Company 1994 -1995
Manager, International Tax – Marion Merrell Dow, Kansas City, MO 1990 - 1994
SUNDSTRAND CORPORATION, Rockford, IL 1983 – 1990
Aerospace manufacturer with sales of $1.5bb, and operations in 15 countries.
Senior International Tax Analyst
EDUCATION
B.S., Accounting minor in Economics Rockford College, Rockford, IL 1982
PROFESSIONAL
Certified Public Accountant – State of Illinois 1983
Member Houston Chapter Tax Executive Institute Current
Panel Speaker Mayer Brown / Bloomberg BNA Energy Tax Conference Sept 2015
Member Detroit Chapter Tax Executive Institute / Co-Chairman International Tax 1999 – 2010
Member Puerto Rico / USA Foundation (PRUSA) Tax Sub-committee 1993 – 1994
Member and Corporate Panel Speaker FSC / DISC Tax Association 1987 – 1990