Form 5472 for Foreign Investors

Charles Kolstad focuses his practice on corporate, partnership and international tax matters. He assists clients in tax planning relating to the acquisition, dispositions and restructurings of business, corporations and partnership; as well as asset financing strategies, including gain-deferral strategies and tax-advantaged financing. Mr. Kolstad has advised start-up and emerging companies on a variety of corporate matters, including raising capital in the private and public debt and equity markets.

Kevin Johnson has worked in the tax controversy area for over 20 years. Early in his career, he joined the IRS as a Revenue Agent and also worked in IRS Appeals. As a result of his experience with the IRS, Mr. Johnson brings a unique perspective and an insider’s understanding of IRS practice and procedure to his tax controversy practice. Mr. Johnson has handled tax controversies at the audit and administrative appeals levels before the IRS, and in litigation before the U.S. Tax Court, Federal District Courts, the U.S. Federal Court of Claims and various Federal Courts of Appeals. 

Dave is a Partner and National Director of International Tax Compliance and Quantitative Consulting Services for Ernst & Young LLP. Based in Cleveland, Dave has over 25 years of experience assisting U.S. multinational businesses with U.S. tax planning and reporting related to their international operations. Dave’s areas of focus include the U.S. foreign tax credit, U.S. export tax incentives (IC-DISC, FSC and ETI), controlled foreign corporation and foreign branch calculations and international mergers and acquisitions. Dave has also assisted clients in determining their U.S. Production Activities Deduction under Section 199. 

Dave has been a frequent speaker for the Council for International Tax Education, ATLAS, the Tax Executives Institute, and the FSC/DISC Tax Association. He authored the July 15, 1996 Tax Notes International article “A FSCful of Dollars: Maximizing FSC Benefits through Transaction Level Pricing” and the November 27, 2000 TNI article on the FSC Repeal and Extraterritorial Income Exclusion Act of 2000. 

- B.A., Business Administration, Duke University 
- J.D., Ohio State University College of Law 
- CPA in Ohio, Illinois, New York and Georgia 
- Admitted to the Ohio Bar

Susan is an international tax director in the Washington National Tax Services office of PricewaterhouseCoopers and is an integral part of the U.S. Firm's inbound solutions practice. 

Susan specializes in advising foreign multinationals on complex U.S. federal income tax issues including compliance, legislative, regulatory and income tax treaty issues and restructuring. Susan's principal areas of expertise include the taxation of international transportation income, the taxation of U.S. real property interests, the taxation of foreign governments, U.S. trade or business and permanent establishment issues, the application of U.S. income tax treaties to foreign multinationals, branch profits taxes, and the application of anti-conduit and earnings stripping rules to inbound financing transactions. Susan also actively advises inbound companies and associations representing large foreign multinationals with respect to technical issues associated with their legislative and regulatory lobbying activities. 

Susan has been with PricewaterhouseCoopers since 1984 and has worked with a wide range of clients during multi-year assignments in Miami, Florida, Caracas, Venezuela, Hong Kong, and, Washington, DC. Susan is also actively involved in authoring the firm's ongoing inbound and U.S. treaty newsalerts intended to alert both client and non-client subscribers of important new U.S. tax developments. 

Susan graduated magna cum laude from the University of Miami in Coral Gables, Florida with a double major in Accounting and International Finance & Marketing and is a CPA, licensed to practice in Florida and Washington, DC. Susan is member of the American Institute of Certified Public Accountants and the Florida Institute of Certified Public Accountants.