Most recently, Mr. Dodge was a Senior Associate at Ernst & Young LLP, where he drafted and analyzed tax documents for a variety of tax-related exposures and issues. He also drafted due diligence reports concerning the transfer of assets subject to the anti-churning regulations, consequences of failure to prepare transfer pricing documents, and debt-to-equity recharacterization. Mr. Dodge has experience researching such tax law topics as the requirements to qualify for an exemption under Section 1202; the triggering of deferred intercompany transactions when an entity exits a consolidated group; and the circumstances under which a corporation triggers taxable income under IRC Section 304. He has prepared structure plans and client reports concerning U.S. tax consequences for acquisitions of partnerships, corporations filing separately, and corporations carved-out of a consolidation group. While in law school, Mr. Dodge served as an Honors Student Intern for the Securities & Exchange Commission. In this capacity, he analyzed and prepared memoranda on legal issues, including jurisdiction, usury, and choice of law.
