The Interplay Problem
On how international and M&A provisions interact in ways most advisors read in isolation — the history of the code, the gaps that remain, and why the uncertainty is where the interesting work lives.
International Tax
Manager · Ernst & Young · Cincinnati, Ohio
CPA
International Corporate Tax Advisory
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About
I'm a Manager at Ernst & Young in International Tax & Transaction Services (ITTS), where I serve as a first-tier advisor to large public companies on the tax implications of cross-border restructuring and international planning. My specality approaches global tax from a US perspective — connecting finance professionals in ways that build and enhance the tax profile of complex multinational businesses. I gravitate toward the technical work: writing tax opinions, untangling cross-border complexity, finding the answer that isn't in the first place you look. I'm particularly drawn to how international provisions interact with corporate and M&A tax and the interplay between sections most people read in isolation, the history of the code that explains why a rule was written, and the gaps and uncertainties that define where the real judgment lives.
Before tax, I was building things. I ran a web hosting company starting at twelve — handled the full stack, platform infrastructure to customer support — and sold it before high school was over. Throughout high school and into college I ran an electronics refurbishing business with enterprise contracts and established vendor relationships. I also ran top-tier game servers, including some of the largest Minecraft servers of the era. I built everything I could from scratch. That instinct — take it apart, understand how it works, build it better — never left. It turns out to be exactly what good tax work requires.
I read constantly — the Journal, the Times, the Economist. Markets are a lens on everything: geopolitics, policy, technology cycles, human behavior. The intersection of capital and ideas is genuinely interesting to me and shapes how I think about the work.
Nothing on this site constitutes tax advice. Any tax-related engagement is conducted exclusively through my employer.
Interests
I'm drawn to the work that requires genuine depth — the interplay between international and corporate or M&A provisions that most advisors read in isolation, the history of a rule that explains why it was written, and the gaps that define where real judgment lives. I like to write opinions, understand the code three layers deep, and find the answer in the places others didn't look.
I've been building things with technology since my teens — running businesses, hosting infrastructure, writing code, taking things apart to understand them. It never stopped being interesting. Most of my free time involves a terminal window and something I probably didn't need to build from scratch but did anyway. The instinct is the same whether the system is a server stack or a tax structure.
I read constantly — the Journal, the Times, the Economist, whatever's worth reading that week. Markets are a lens on everything: geopolitics, technology cycles, policy, human behavior. I find the intersection of capital and ideas genuinely fascinating and follow it closely. Where capital flows often tells you more about what's actually happening than the story being told about it.
Writing
On how international and M&A provisions interact in ways most advisors read in isolation — the history of the code, the gaps that remain, and why the uncertainty is where the interesting work lives.
International TaxA through-line from a twelve-year-old's server infrastructure to international tax advisory at a Big Four firm — and what building things from scratch teaches you about how systems break.
BackgroundContact
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