STANLEY C. RUCHELMAN concentrates his practice in the area of tax planning for privately held transnational business operations with emphasis on intercompany transactions. Working closely with foreign counsel, Mr. Ruchelman has represented companies in matters involving the I.R.S., and has counseled corporate clients on transfer pricing issues, worldwide reorganizations, and structuring investment in the United States. Mr. Ruchelman has authored numerous monographs on international taxation for a variety of publications and treatises. In addition, Mr. Ruchelman is a frequent lecturer on that subject, having spoken at the Practicing Law Institute, New York University Tax Institute, the American Bar Association, the International Fiscal Association, and other organizations. He has chaired the introductory and intermediate seminars on U.S. international taxation for Executive Enterprises and has spoken on Canada-U.S. cross border issues for CITE. Mr. Ruchelman served as the U.S.A. reporter for the Foreign Lawyers Forum of the American Bar Association Section of Taxation.

Mr. Ruchelman was an international tax partner at a predecessor of Deloitte & Touche where he practiced for eight years representing clients involved in cross border trade and investment. Mr. Ruchelman was a Senior Attorney in the Legislation & Regulations Division of the Office of Chief Counsel, Internal Revenue Service, where he participated in the negotiation of income tax treaties and the development of legislative and regulatory policy affecting international business. Prior to that, Mr. Ruchelman was an Attorney Adviser to the Hon. Charles R. Simpson, U.S. Tax Court.

Mr. Ruchelman is a former Chair of the Committee on U.S. Activities of Foreigners and Tax Treaties, Section of Taxation, American Bar Association and the International Tax Committee, Section of International Law and Practice, American Bar Association. Mr. Ruchelman served on the National Council of the International Fiscal Association -- USA Branch.

Mr. Ruchelman received his J.D. Degree with honors from George Washington University (1972) and his undergraduate degree from Brooklyn College (1968).

February 8, 2007

DORIS S. HSU concentrates her practice in the income taxation of domestic and foreign individuals and businesses. She advises clients in cross-border mergers and acquisitions (including use of income tax treaties), business formation, restructuring and reorganization, joint ventures, stock and asset purchases and sales and executive compensation. She also represents clients in examinations by the I.R.S. and state and local tax authorities.

Ms. Hsu received her LL.M. degree in tax from New York University School of Law (1996), J.D. (cum laude) and M.S.L. (magna cum laude) degrees from Vermont Law School (1995), and B.A. degree in English from National Taiwan University (1992). Ms. Hsu is fluent in Mandarin Chinese and Taiwanese.

ROBERT G. RINNINSLAND concentrates his practice on corporate tax planning for the U.S. based multinational corporation. He has more than 25 years of corporate tax experience in all areas of domestic and international corporate tax law and has held positions ranging from International Tax Counsel to Chief Tax Officer responsible for the worldwide tax affairs.

Mr. Rinninsland has been responsible for planning and compliance involving international joint ventures, legal entity restructuring, cash repatriation strategies, transfer pricing ,and effective tax rate planning and analysis. Most recently, he was involved in implementation of policies and procedures for compliance with the contemporaneous documentation rules related to the best method of transfer pricing required under Code §§ 482 and 6662.

In addition, he has advised clients in ways to comply with the Sarbanes-Oxley legislation and related S.E.C. regulations as they relate to the operations of the corporate tax department. He has lectured and written on the topic for CITE (the Council For International Tax Education). Mr. Rinninsland has also lectured on the domestic and international aspects of F.A.S. 109, which deals with tax accounting procedures.

Mr. Rinninsland began his career as an international tax attorney for the Internal Revenue Service in Washington D.C. There, he specialized in the taxation of U.S. based multinational companies and individuals, reviewing transactions involving U.S. income tax treaties, Subpart F, and the creditable nature of foreign taxes.

SHERIF ASSEF is responsible for economic analysis in transfer pricing projects of the Ruchelman Law Firm. Dr. Assef holds a Ph.D. in economics from Fordham University and is in charge of the New York City office of Ceteris Group, an economic consulting firm that specializes in transfer pricing and valuation consulting.

Dr. Assef has advised clients on all stages of the transfer pricing process, including global documentation, planning, implementation, and controversy management. He has worked with clients in financial services, publishing, apparel, industrial manufacturing, commodities, information technology, telecommunications, oilfield services, engineering, and construction industries.

Previously, he was with Ernst & Young LLP, where he led the financial services transfer pricing practice in New York. He assisted clients in analyzing a variety of related-party transactions, including the global trading of financial instruments, asset management services, brokerage services, the sharing of banking fees, insurance and reinsurance transactions, loans, guarantees, management services, and administrative services

SIMON PRISK concentrates his practice in the areas of corporate, securities and finance. Mr. Prisk has advised clients on matters relating to equity and debt financings, private placements and mergers and acquisitions. He also advises clients on all aspects of general business and corporate law and on commercial real estate matters, where he focuses on sales, acquisitions and leasing. His clients have included media and transportation companies, overseas mineral joint ventures, and companies in the high-tech segment.

A native of New Zealand, Mr. Prisk’s experience in New York followed four years of private practice in the litigation and corporate department of a New Zealand law firm.

Mr. Prisk received his LL.B. from Canterbury University in Christchurch, New Zealand and his L.L.M. from Columbia University in New York City. He is admitted to practice in New Zealand and New York.

EDWARD C. NORTHWOOD is the resident U.S. attorney in the Toronto Office of the firm. He concentrates his practice in U.S. domestic and international tax matters involving estate planning, family business planning, charitable planned giving, trust and estate administration, and executive compensation. Mr. Northwood is a frequent lecturer and has presented papers relating to cross border planning issues for the Canadian Chapter of the Society of Trust and Estate Practitioners (“STEP”), the American College of Trust & Estate Counsel (“ACTEC”), the Canadian Bar Association (“CBA”), the American Law Institute - American Bar Association (“ALI-ABA”), the New York State Bar Association (“NYSBA”), and The Canadian Tax Foundation. He is a Fellow of ACTEC, an academician of The International Academy of Estate and Trust Law, a member of the Toronto Estate Planning Council, and a member of the Toronto branch of the STEP, where he serves on the Board of Directors.

Mr. Northwood practiced for over 25 years with Hodgson Russ LLP, and for several years served as the tax partner resident in that firm's Toronto office.

Mr. Northwood received his J.D. degree, cum laude, from the Law School of the State University of New York at Buffalo, an MA degree from the State University of New York at Albany, and his undergraduate degree from Brown University.

Mr. Northwood's practice is limited to U.S. law.

ANDREW MITCHEL has extensive experience in tax planning for multinational businesses. He has more than 18 years of tax experience in areas of international and domestic taxation. Mr. Mitchel was a Senior Manager of International Tax Planning for PepsiCo, Inc. where he provided tax planning advice on acquisitions, divestitures, and restructurings throughout the world. Mr. Mitchel also worked in the International Tax Department of United Technologies Corporation, after beginning his career in public accounting. Mr. Mitchel is a frequent lecturer for the International Fiscal Association and recently presented on International Aspects of Entity Classification.

Mr. Mitchel received his LL.M. degree in Taxation from New York University, his J.D. degree from The University of Connecticut School of Law and his B.A. degree in Economics from Eastern Connecticut State University (Summa Cum Laude). He is a member of the International Fiscal Association, the American Bar Association (Tax Section), the Connecticut Bar Association, and the Connecticut Society of Certified Public Accountants. Mr. Mitchel is admitted to the bar in Connecticut.