Vesselin Tzotchev

Current

Senior Tax Manager at US Tax & Financial Services, Sarl
Vice President (Pro-bono) at Canadian Bulgarian Association, Inc.

Past

Tax Manager at Glenn M. Gelman & Associates
Owner, Director of U.S. Tax at US CAN TAX Consultants Limited
U.S. Tax Manager at SB Partners LLP

U.S. Tax Senior Associate at PricewaterhouseCoopers LLP
U.S. Tax Associate at Big 4 firm at Deloitte
Associate at Steven K. Vinje, Attorney-At-Law (www.expatriate-tax.com) (Sole Proprietorship)
Summer Intern at Gap Inc.
Translator & Legislative Development Consultant at Bruckhaus Westrick Stegemann
Senior Tax Lawyer at Bulgarian Ministry of Finance
Privatization Lawyer at Freelance Privatization Consultant (Self-employed)
Jurist-consult (part-time) at Investment Fund "Development" KDA
Articling Student (Stajant Sudia) at Bulgarian Ministry of Justice

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Education

Golden Gate University, School of Law
Universitet za nacionalno i svetovno stopanstvo
Sofiiski universitet Sv. Kliment Ohridski

National Classical Lyceum St. Konstantin-Kiril the Philosopher

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Recommended

4 people have recommended Vesselin

Connections

309 connections

Industry

Accounting

Websites

Vesselin Tzotchev’s Summary

• Federal and international tax research and planning including mergers, divestitures, asset acquisitions and foreign tax credit planning
• Interpret & apply international tax treaties (Forms 8833, W-8BEN etc.)
• Review federal corporate, consolidated, partnership, state, individual, trust and estate returns
• Review international tax returns (Forms 1120-F (branch), 5471,5472, 8865,8858,1118, 1040NR, 1116) and prepare interest and stewardship allocations
• Analyze proposed legal and tax structures for domestic and international entities
• Monitor and analyze proposed U.S. and foreign tax legislation and identify appropriate positions
• Prepare quarterly FAS 109 calculations and FIN 48 disclosures for US and foreign subsidiaries
• Maintain earnings and profits analysis for repatriation of U.S. dividends and complex model of cash flow projections
• Draft foreign tax disclosure statements for the federal consolidated tax return
• Manage IRS and state audit issues
• Manage income tax planning and compliance for high net worth individuals and executive compensation
• Prepared & reviewed tax returns for US & Canadian inpatriates/expatriates
• International assignment policy design (such as tax equalization, tax protection & other types of tax-related programs), program implementation, research & analysis of foreign country tax laws
• Drafted and reviewed tax and commercial documents including tax disclosure statements, reorganization, partnership, operating and shareholders' agreements
• Engaged in estate and trust planning, including document preparation and interpretation and trust reformation
• Advised clients regarding succession planning for business enterprises, buy-sell and redemption agreements and charitable gift tax planning
• Supervised and coached new and experienced staff members

Please visit my personal website: http://www.uscantax.com

Vesselin Tzotchev’s Specialties:

Corporate, International, SALT tax compliance and consulting for diverse industries.

Vesselin Tzotchev’s Experience

Senior Tax Manager

US Tax & Financial Services, Sarl

(Privately Held; Accounting industry)

July 2009 — Present (5 months)

We specialize in US, UK and Canadian tax, financial and legal work for Americans and Canadians doing business in the UK and Europe and Europeans doing business in the US and Canada. 60% of our business is US & UK tax compliance, individual, corporate, partnership, trust and estate tax and 40% is US/UK cross border tax and financial consulting. We have offices in London, Geneva and Zurich.
Vice President (Pro-bono)

Canadian Bulgarian Association, Inc.

(Non-Profit Organization Management industry)

January 2006 — Present (3 years 11 months)

Bulgarian community organization based in Ontario, Canada.
Tax Manager

Glenn M. Gelman & Associates

(Privately Held; Accounting industry)

January 2009 — May 2009 (5 months)

• Review tax returns of small & medium size corporations, pass-through entities and their owners in the construction, real estate development and management, captive insurance industries.
• Draft tax research memoranda on federal and multi-state tax issues such as 1031 exchanges, COD income exclusions, taxation of damage awards, Water’s Edge elections,
• Manage and coach 2 associates and 2 senior tax consultants.
Owner, Director of U.S. Tax

US CAN TAX Consultants Limited

(Accounting industry)

January 2008 — December 2008 (1 year )

• Outsourced U.S. tax services of regional and small accounting firms in GTA and South Western Ontario
• Represented Canadian multinational before the Internal Revenue Service
• Advised Canadian insurance group of companies on tax effective business expansion in the U.S.
• Advised Canadian resident individuals and companies on Canada – U.S. income tax treaty applications
U.S. Tax Manager

SB Partners LLP

(Partnership; Accounting industry)

August 2005 — December 2007 (2 years 5 months)

• Tripled the U.S. tax practice’s revenues while reducing the number of tax returns by 20%
• Advised on cross-border investments and financings of over $100M
• Prepared and reviewed FAS 109/FIN 48 tax provisions for U.S. multinationals
• Consulted U.S. technology company and Canadian subsidiary on FAS 123(R) transition
• Prepared 25 state tax nexus study for a cross-border transportation company
• Prepared 29 years of PFIC and FPHC studies. Consulted on the sale of a private company
• Prepared multi-year Earnings and Profits and Basis studies for Canadian subsidiaries of U.S. multinational, utilized section 965 one-time dividend repatriation opportunity
• Consulted Canadian investors in implementing section 1031 like-kind exchanges in the U.S. Prepared numerous FIRPTA returns
U.S. Tax Senior Associate

PricewaterhouseCoopers LLP

(Partnership; PWC; Accounting industry)

2003 — 2005 (2 years )

Canada - U.S. corporate tax Big 4 practice
• Prepared numerous consolidated, multi-state, FIRPTA, Forms 1118, 5471/2, treaty-based and branch U.S. corporate tax returns for over 50 clients. Prepared tax provisions. Liaised with IRS & state tax authorities on various compliance issues. Assisted in legal research, drafted memoranda and presentations on cross-border business combinations as well as:
• Computed the tax benefits of Section 338 asset acquisitions and updated on transfers of built-in-losses
• Cross-border financing structures such as (tower, debt financing, factoring of U.S. receivables, repo financing)
• Computed foreign E&P (Sun Chemicals - 10+yrs), PFIC and QEF (MLF), M&A basis adjustments
• Foreign tax credit, and sec. 199 production activities deduction update under the AJCA оf 2004
• Planning for U.S. tax treaty benefits
U.S. Tax Associate at Big 4 firm

Deloitte

(Partnership; Management Consulting industry)

2000 — 2003 (3 years )

2000 - 2001 - San Francisco Office - Corporate Tax, Tech.com practice
• Prepared individual, partnership, LLC, and corporate tax returns, estimates, and extensions for Real Estate Investment, Emerging Technology (TMT) and International Tax clients. Prepared income tax provisions for financial reporting and accounting purposes. Liaised for clients in federal and state income tax audits.
• Researched issues, prepared slides for a presentation on a “German double dip” tax strategy
• Member of a consulting and compliance TMT team for incorporation of 5 “C” corps into an LLC through 5 private placements, computed in–/outside basis of +500 venture capital investors

2001 - 2003 - Toronto Office - International Assignment Solutions practice
• Prepared Canadian and US individual tax returns, tax equalization calculations, certificate of coverage applications for Canadian and US expatriates and foreign nationals. Liaised on behalf of clients with CCRA and IRS, efficiently resolving residency, foreign tax credit (FTC), and incentive compensation controversies. Researched various tax law and business issues and consulted senior specialists to maximize clients’ results.
• Presented a seminar on the Canadian and U.S. treatment of wash sales, straddles and stop loss rules
Associate
Steven K. Vinje, Attorney-At-Law (www.expatriate-tax.com) (Sole Proprietorship)

(Sole Proprietorship; 1-10 employees; Law Practice industry)

January 2000 — June 2000 (6 months)

Expatriate Tax Law Boutique Firm
Summer Intern

Gap Inc.

(Public Company; GPS; Retail industry)

May 1998 — July 1998 (3 months)

International Tax Department, San Bruno, CA

Developed a model for transfer pricing allocations of the headquarter expenses and transactions with related parties in 50 countries. Provided tax audit defense for IRS and Revenue Canada transfer pricing audits. Prepared Canadian Form T106; US Forms 1118, 5471.
Translator & Legislative Development Consultant

Bruckhaus Westrick Stegemann

(Partnership; 501-1000 employees; Legal Services industry)

1996 — 1997 (1 year )

PHARE program for Approximation of Bulgarian Legislation to EC Law
Senior Tax Lawyer

Bulgarian Ministry of Finance

(Government Administration industry)

May 1995 — May 1997 (2 years 1 month)

Represented the Tax Commissioner before the Bulgarian Courts in income and excise tax cases.
Reviewed Tax Assessment Acts drafted by 40 agents.
Developed EU harmonized tax legislation.
Privatization Lawyer
Freelance Privatization Consultant (Self-employed)

(Self-Employed; Myself Only; Law Practice industry)

November 1994 — April 1995 (6 months)

Due diligence and pre-privatization analysis of Energocabel EAD and Shamot EAD.
Jurist-consult (part-time)

Investment Fund "Development" KDA

(Public Company; 11-50 employees; Financial Services industry)

November 1993 — November 1994 (1 year 1 month)

Prepared due diligence analyses of state-owned companies for privatization.
Articling Student (Stajant Sudia)

Bulgarian Ministry of Justice

(Government Agency; 10,001 or more employees; Legal Services industry)

November 1993 — November 1994 (1 year 1 month)

Mandatory trainee services in the Bulgarian judicial system.

Vesselin Tzotchev’s Education

Golden Gate University, School of Law

LL.M. , U.S. Tax Law , 1997 — 1998
Universitet za nacionalno i svetovno stopanstvo

Accounting & Control 1994 — 1997
Sofiiski universitet Sv. Kliment Ohridski

J.D. , Law , 1987 — 1991
National Classical Lyceum St. Konstantin-Kiril the Philosopher

High School Diploma ,

Additional Information

Vesselin Tzotchev’s Websites:

Vesselin Tzotchev’s Interests:

Canada - U.S. cross-border mergers & acquisitions and tax planning. Canadian - Bulgarian cultural and business relations.

Vesselin Tzotchev’s Groups:

Licensed Attorney at Sofia Bar Association
Licensed to practice before the U.S. Internal Revenue Service
Associate Member of The State Bar of California (Tax Section)
Vice President of the Canadian Bulgarian Association (pro-bono)
Treasurer of the Bulgarian Eastern Orthodox Church, St Dimitar (pro-bono)
Founding Member of Institute of Contemporary Art, Sofia