Cheryl Tedder

Cheryl Tedder has provided international tax consulting and compliance services to U.S. and non-U.S. multinationals and partnerships for over 17 years. During her career, she has consulted with respect to reorganizations, ownership of intellectual property, cash repatriation, legal entity rationalizations, and inversions for clients in the technology (hardware and software), retail, food and beverage, apparel, life sciences, biotechnology, and utility industries.

Services provided on recent engagements include:

• Research with respect to predominant character of income as either services or rental income, and what this means for U.S. tax purposes.
• Analysis of implications under IRC §367(b) and accompanying regulations to determine a taxpayer's all-E&P inclusion.
• Subpart F income analyses with respect to CFC sales and services activities.
• Legal entity classification analysis and associated U.S. reporting requirements for a taxpayer's non-U.S. rep offices.
• Preparation of U.S. tax calculations to estimate a client's FY21 GILTI inclusion.
• Review of multiple Forms 5471, 8858, 8990, and 8992, and the corresponding U.S. tax calculations for Subpart F, GILTI, and FDII, as part of recent U.S. tax compliance process.

Prior to joining Andersen, Cheryl was a senior manager with KPMG specializing in international tax services in San Francisco.