“What can I do with a Master of Taxation (MT)?” This is a common question among prospective students. The MT is the only program of its kind in Oregon, but it has the highest rate of post-graduation employment of any of Portland State University’s Graduate Business School programs. MT students emerge from their degree with a highly unique, complex and versatile skill set that bears great strategic importance for any company.
Professor Bill Ramirez teaches Corporate Tax and International Tax in the MT program and Introduction to Taxation and Advanced Tax to undergraduates. Here, he shares his own highly international, multidisciplinary career experience and insights, including advice for students interested in international tax work.
Can you give a brief summary of your education and professional tax experience?
My mother told her friends that I had more degrees than a thermometer. I earned a bachelor’s in business administration from Texas Tech, a J.D. from the University of Iowa and a master’s of law in taxation from DePaul University.
During my career, I worked in four countries on three continents: Asia, Europe and North America. I have 33 years as a tax professional: 12 years in the U.S. in a variety of roles, 6 years in Belgium as European tax director for Levi Strauss, 10 years in Switzerland as international tax counsel for Philip Morris, and 5 years in Hong Kong as Asian tax director for Philip Morris. I worked across many departments, including accounting, finance, human resources, legal and treasury. The scope of work enabled me to utilize both my legal and tax knowledge.
Like most young professionals in this field, I spent the first few years of my career in tax compliance. In my first year in the Chicago office of PriceWaterhouseCoopers, I devoted my time to preparing tax returns for U.S. citizens working abroad and for foreign nationals working in the U.S. As my career progressed, I did less compliance and more planning.
Which aspect of your career have you enjoyed the most?
The scope of my experience is quite broad. It includes acquisitions, dispositions, restructurings, formulating transfer pricing policies, preparing transfer pricing documentation, defending transfer pricing policies during tax examinations, negotiating agreements between tax authorities to avoid tax controversies, and managing competent authority processes when cross border disputes arise.
What I enjoyed the most was the opportunity to do some international tax advocacy. I was in Europe when the Iron Curtain between East and West came down, and I gained firsthand experience when I participated in meetings with tax officials from Kazakhstan, Lithuania and Russia as they worked to make their economies attractive to foreign investment. In Asia, I met several times with the Singapore Economic Development Board to give a Westerner’s view on how Singapore could encourage and retain foreign investment. From 2003 to 2008, I was part of a group sponsored by the International Bureau of Fiscal Documentation that met quarterly with the Chinese tax authorities. The result of the four year collaboration was a new Chinese tax law that took effect in 2008.
What got you interested in teaching?
I had no formal teaching experience before I began teaching at PSU. When based in Europe with Philip Morris, I took the initiative to organize annual tax conferences for our affiliate finance personnel who assisted with tax matters. I prepared the agenda, selected topics and invited speakers. The meetings were held in various locations, including Amsterdam, Barcelona, Montreux, Nice and Paris. I have also had the opportunity to speak at tax conferences around the world, including delivering speeches in Bangkok, Beijing, Hong Kong, London, Moscow, New York City, Shanghai and Singapore. Over time, I got a reputation for being able to explain complicated tax concepts in layman’s terms.
How do your MT students benefit from your experience?
Given the breadth and length of my experience, I can share real-world stories. I have seen tax issues not only from a U.S. perspective, but also international perspectives.
My students also learn the value of their expertise. For many business professionals, tax is a mystery that is difficult to penetrate or understand. Tax is one of the major costs that a business can incur. It is important that the tax function have a seat at the table when formulating business strategy.
What type of professionals are drawn to international tax careers?
An individual who is a problem solver and who enjoys working in a complex environment would be interested in a career in international tax. An international tax practitioner has to deal not only with the intricacies of U.S. tax law, but must have a working knowledge of the various tax laws of foreign countries. One could compare international tax planning to working with a Rubik’s cube.
How should your students prepare for success after the MT program?
After graduation, a student who pursues an international tax career should be prepared for a career of continuous learning. The pace of change in international tax is accelerating and the complexities of the issues involved is increasing. This means ample opportunity for those individuals who choose a career in international tax.
Let us look at the U.S. In 2017, Trump passed the Tax Cuts and Jobs Act, which made the biggest changes to the U.S. international tax system since 1986. As of this writing, Biden has indicated that he wants to make significant changes to the U.S. international tax system. An international tax practitioner, however, must not only look at U.S. tax developments but also must keep an eye on what is going on outside the U.S. The Organization of Economic Cooperation and Development (OECD) is coordinating a review by 137 countries of the international tax system. The OECD may announce as soon as June 2021 fundamental changes that may take effect in 2022. In short, what worked well five years ago does not work today, and what works today may not work in two years.
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