Principal in the Mergers and Acquisitions group of PwC's Washington National Tax Services Office, which helps clients evaluate a variety of possible structures, complex international arrangements, and sophisticated financing mechanisms.
His expertise is centered in the federal consolidated return arena for clients with global footprints. He focuses on designing creative solutions to minimize liabilities and maximize use of assets to the greatest extent possible, through tools including elimination of excess loss account (ELAs), transfers of intercompany receivables, and internal restructuring transactions.
Mr. Friedel is a Member of the District of Columbia and Virginia State bar associations. He is formerly Attorney/Adviser, Office of Chief Counsel, Internal Revenue Service.
LL.M., Taxation, Georgetown University
J.D., American University Washington College of Law magna cum laude
B.S., Economics, University of Pennsylvania Wharton School of Business
Bloomberg Tax Management Portfolios
Earnings and Profits discusses the principles and rules associated with earnings and profits (E&P) and analyzes the tax effects on E&P of corporate distributions.