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Theodora Cudritescu

Taxation - thetaxnetwork.net

11 YEARS OF
EXPERIENCE

0 TIMES
RECOMMENDED

0 ARTICLES
POSTED

  • Aug 19, 2015

    JOINED IP NEXUS

  • Toronto, Canada

    Active Country

  • English

    Languages

  • Practice Areas

About

• Experience (11 years): 5 years US Tax; 3 years International Tax (Canada); 1.5 years International Tax (US); 3 years M&A Tax; 4 years Business Tax; 4 years Commodity Tax.
• Superior skill in tax research and writing and tax advisory; risk assessment and mitigation;
• High level professional expertise in interpreting and applying Tax Laws: Income Tax Act (Canada), Excise Tax Act (Canada), Internal Revenue Code (US), Income Tax Treaties.
• Demonstrated decision making and problem solving skills; strategic project management.
• Demonstrated ability to communicate and implement internal policies; to assess applicable project requirements and monitor legislative/policy changes including government guidance.
• High level communication, computer skill; result & relationship oriented, constantly evolving.
• MTax Thesis: "Withholding Tax Systems"- an analysis of the European Union taxation policy and procedures on the inflow/outflow of capital.

Reduced the audit assessment. Excluded gain on sale of shares from ITC rate (unresolved with accounting firms) and saved 17 million in ITC rate impact. Investigated and assessed 10 million intercompany payment. Tax documented over 1000 client financial accounts, resolved over 500 QI related tax queries; attended directors’ meetings on behalf of the AVP of tax. Development and coaching of tax professionals and other junior tax staff members. Contributed to business development through tax publications. Transformed and established business tax practices. Obtained tax refunds retroactively. Promoted within 6 months to Senior Manager within a worldwide organization.

Work history

Global Tax Governance-Manager
TD
January 2015 – March 2015 (3 months)Toronto, Canada Area
Provided tax services on a short term contract.

TD Group worldwide consolidated tax provision (the US and Offshore subsidiaries) review and sign off; OCI F/S disclosure; oversight over tax risk management; responsible for regulatory reporting (Tax Transparency Initiative; CBA; SOX; Basel III; Corporate Responsibility report); Tax Estimates Committee presentation and minutes; review; research and documentation of worldwide top of the house taxation issues including International and Domestic reorganizations of capital, tax planning and tax advisory initiatives, Pt VI.1 tax; Recommendations and implementations of changes; integration of the IFRS process into tax country team reporting; Tax due diligence; Quarter-end tax reporting;

HAYS North America
Senior Management Consultant-Taxation (contract) Oct 7, 2013-May 27, 2014
Reports to Top Management
Ensure the team is fully up to date on changes to relevant tax laws; Implement quality controls to mitigate risk; Coordinate the staff’s tax work; tax process transformation;
Provide support, advice, training to business units re application of the relevant Federal and provincial tax laws; Establish internal policies and monitor Canadian and US tax policies and interpret tax laws and regulations; Draft/revise reports and opinions on tax matters (for presentation to senior management); Pt XIII tax; Review and approve US tax returns; Research US Tax law & US W/H Tax; Application of US-UK Tax treaty; assess implications of cross border UK/US/Canada transactions.

HSBC Bank Canada ​ Vancouver, BC
Manager, Income Tax/ Senior Manager, Operational Tax (contract) Apr 2012 – Jun 2013
Reports to AVP
Manage tax accounting, provisioning and reporting for Canadian subsidiaries; Implement quality controls and improvement to tax provision and reporting processes; tax planning re Pt XIV tax and interest deduction; Pt VI tax; Pt. XIII.1 tax; Establish, revise and monitor Canadian tax policies; Perform risk assessment and mitigation and write audit report (20 pg) w.r.t. Canadian and non-resident slip reporting within the Bank; Provide support, advice, to business units re application of the relevant tax laws; Liaise with finance team; other teams within the organization on project deliverables.

CA Firms [Sacks; MG LLP; MDP LLP] Greater Toronto Area, Ontario
Senior Tax Accountant, May 2007- Jan 2011
Reported to Senior Manager and Partner
Ensure the team is fully up to date on changes to relevant tax laws; Provide support, advice, training to the audit team and clients re application of the relevant Federal and provincial tax laws; Research, interpret and apply tax laws and regulations; Draft/revise memos and opinions on tax matters (for presentation to partners; to lawyers for corporate reorganization purposes and for files); Follow up on analyses of taxation risks and supervise the implementation of action plans with appropriate teams;
Corporate reorganizations: review of legal and financial files and establish tax attributes of capital as well as tax implications of capital reorganizations; assess applicability of Income Tax Act to the reorganizations of capital; wind-ups; amalgamations; transfer of assets; sale of business; Prepare business and real estate valuations; cross border individual transactions and estate planning (Canada/US) including application of Canadian ITA; US IRC and Canada-US tax treaty; Foreign affiliate reporting; Foreign insurance company; corporate and individual tax planning; partnership transfer of assets;
HSBC Securities, Merrill Lynch HSBC Toronto, Ontario
US Tax -QI Specialist (US w/h tax, QI rules), Feb 2003 – June 2004
Reported to AVP Tax
Ensure the organization is fully up to date on US QI tax laws; Implement quality controls
Maintain excellent relationships with internal clients and tax authorities; Assess applicability of the Internal Revenue Code and regulations to specific tax, client related situations; establish, communicate and implement policies for tax payments and filings in respect of US withholding tax; review and cure deficiencies on client accounts in preparation for the QI tax audit; assess applicability of correct tax form to specific accounts and review validity of tax forms; communicate on behalf of tax department in respect of QI tax related queries. Attended 15th Annual Forum on International Tax Withholding & Information Reporting; June 11, 2003 Manhattan, New York

Education and qualifications

University of Waterloo
MTax, Taxation
2004 – 2007

University of Toronto - Rotman School of Management
BComm, Accounting/Economics
1998 – 2002
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