TAX CONTROVERSY QUALIFICATIONS

Experience. Resolution-Focused. Data Driven Insights.

OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3

SERVICES . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 4

EXPERIENCE . . . . . . . . . . . . . . . . . . . . . . . . Page 5

TEAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 6

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . Page 7

ABOUT ANKURA . . . . . . . . . . . . . . . . . . . . Page 8

TABLE OF CONTENTS

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NEW INSIGHTSOur experience with complex financial systems, global operating structures, and intercompany accounting methods helps uncover new insights.

NARROW THE ISSUES IN DISPUTESWe work with outside counsel and their clients to develop accounting, valuation, and economic analyses to resolve issues at audit, appeal, or to otherwise narrow the topics in dispute.

STIPULATION BEFORE LITIGATIONWe have a track record of convincing opposing counsel (and their experts), to adopt our analyses before the exchange of expert reports or before trial.

COMPELLING EXPERT TESTIMONYOur experts have testified in the US Tax Court and other venues. We also provide the foundation for testimony by other financial, industry, economic or technical experts.

TAXPAYERS AND OUTSIDE

COUNSEL VALUE ANKURA BECAUSE:

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• ACCOUNTING

• VALUATION

• EXPERT TESTIMONY

• CONSULTING SERVICES

• U.S. Tax Court Litigation

• District Court Refund Litigation

• Audit and Appeal Proceedings

• Criminal Tax Investigations

• Accounting for Income Tax Investigations

• Tax Practitioner Malpractice Litigation

• Tax Compliance Monitorships

• Post Transaction Litigation Involving Significant Tax Issues

• Consumer Class Action Litigation Involving State/Local Taxation Practices

SCOPE OF SERVICES

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• Financial services and insurance

• Diversified manufacturing

• Software

• Online retail

• Personal computers and peripherals

• Medical devices/products

• Branded consumer products (food, specialty products, and apparel)

EXPERIENCE

• THE COCA-COLA COMPANY V. COMMISSIONER

• TYCO V. COMMISSIONER

• MEDTRONIC V. COMMISSIONER

• AMAZON.COM V. COMMISSIONER

• VERITAS V. COMMISSIONER

• BNSF V. UNITED STATES OF AMERICA

• P&G V. UNITED STATES OF AMERICA

1 The above-referenced matters may have taken place before our professionals joined Ankura.

ANKURA’S TAX CONTROVERSY TEAM HAS BEEN INVOLVED IN THE LARGEST TAX DISPUTES IN UNITED STATES HISTORY.1

• COMPAQ V. COMMISSIONER

• SEAGATE V. COMMISSIONER

• PERKIN-ELMER V. COMMISSIONER

• NATIONAL SEMICONDUCTOR V. COMMISSIONER

• NESTLE V. COMMISSIONER

• UPS V. COMMISSIONER

• Analytical measuring instruments

• Food supplement, health, and beauty products

• Transportation and logistics

• Mining and precious metals

• Integrated oil and gas

• Pharmaceuticals

• Communications and media

OUR INDUSTRY EXPERIENCE INCLUDES:

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ROB WENTLAND CPA, CFF Chicago

ANKURA’S TEAM INCLUDES THE FOLLOWING EXPERTS

GENE DEETZ CPA, CFF, ABV, ASA, CEIV New York

MIKE KENNELLY CPA, CFF, ABV, ASA, CIRA, CDBV Chicago

DAVE MOES CPA, CFF Chicago

JOHN CIANCANELLI CPA(R), CFA, MBA Chicago

TESTIFIERS

ACCOUNTING

VALUATION

ACCOUNTING

VALUATION

ACCOUNTING ACCOUNTING

VALUATION

ELIZABETH HUTCHINS | MBA, CFE, CBIP | Chicago

MIKE ST. MARTIN | CFA, ASA, MBA | Chicago

NAREN PATEL | CPA, CFE, CITP | Chicago

MIKE PESCE | CPA, ABV, CEIV | New York

BRAD PINNE | CBIP | Chicago

CHRIS ROBINSON | CPA | Chicago

JOHN ROLLINS | ASA, CFE, CAMS, MBA | New York

JONATHAN RUSH | CPA(R), CBIP | Chicago

ACCOUNTING VALUATIONCONSULTING EXPERTS

ABV Accredited in Business ValuationASA Accredited Senior AppraiserCAMS Certified Anti-Money Laundering SpecialistCBIP Certified Business Intelligence ProfessionalCDBV Certification in Distressed Business ValuationCEIV Certified in Entity and Intangible ValuationsCFA Chartered Financial Analyst

CFE Certified Fraud ExaminerCFF Certified in Financial ForensicsCIRA Certified Insolvency & Restructuring AdvisorCITP Certified Information Technology ProfessionalCPA Certified Public AccountantCPA(R) Registered Certified Public AccountantMBA Master of Business Administration

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REFERENCES

ATTORNEYS FROM THE FOLLOWING LAW FIRMS CAN COMMENT ON THE QUALITY, INTELLECTUAL RIGOR, AND RELIABILITY OF OUR TAX CONTROVERSY WORK:

• Baker McKenzie Chicago, New York, Palo Alto, Washington, D.C.

• King & Spalding LLP Washington, D.C., Atlanta

• Mayer Brown Chicago, New York

• McDermott Will & Emery Chicago, New York

• Miller & Chevalier Chartered Washington, D.C.

• Morgan, Lewis & Bockius LLP Chicago, Palo Alto, Washington, D.C.

• Skadden, Arps, Slate, Meagher & Flom LLP Chicago, New York, Palo Alto, Washington, D.C.

• White & Case LLP Washington, D.C.

WE ALSO ENCOURAGE YOU TO SPEAK WITH OUR TAXPAYER CLIENTS THAT CAN COMMENT ON:

• Our positive working relationships with their accounting, tax, financial reporting, IT and product development departments,

• Our transparent budgeting and billing processes, and

• Our ability to work through difficult issues.

© 2019 Ankura Consulting Group, LLC

As the volume and complexity of disputes, business risks, and regulatory challenges continues to grow, leading companies and their counsel know that the right expert services team can make or break a case.

Ankura brings the functional expertise, industry depth, expert specialization, and global experi-ence to support companies and counsel throughout all phases of litigation, arbitration, or regula-tory proceedings.

ABOUT ANKURA