Title: Demystifying the Expatriate Assignment Process
1(No Transcript)
2Meeting Agenda
Demystifying the Expatriate Assignment Process
Carol-Ann Simon, Perkins Co Emerging
International Relocation Program Issues, Risks
and Best Practices Gary P. Tober, Garvey
Schubert Barer Global Assignment Policy Overview
Joseph Willis, Nike Improve Effectiveness of
Global Mobility Jennifer Fu, Banfield/Mars,
Inc. Destination Service Provider Delayne
Romson, International Expatriate Consulting,
Inc.
3Carol-Ann Simon Perkins Co, Shareholder
Carol-Ann is a tax shareholder and director of
our Expatriate Tax practice group. With over 25
years of experience, in the US and Canada,
Carol-Ann has the unique ability to understand
the dual-country implications of a foreign
assignment. Her expertise includes coordinating
global tax compliance, tax effective
compensation, cross border planning, employee
relocation issues and tax equalization policies.
Her clients have included hundreds of
international businesses ranging in size from
family-owned to large multinational companies.
Most recently, Carol-Ann obtained Certifying
Acceptance Agent (CAA) status with the IRS,
allowing her to assist foreign nationals in the
applications for Individual Taxpayer Identifi
cation Numbers (ITIN). Carol-Anns certification
will streamline the process of obtaining an ITIN
as she will be able to locally review the
original documents necessary and certify the
application for the IRS. Prior to joining
Perkins Company, Carol-Ann was the partner in
charge of BDO Seidmans Expatriate Tax Services
group and served as BDO Seidmans U.S. liaison to
the BDO International Center of Excellence for
Expatriate Tax Services. In addition to her time
with BDO, Carol-Ann developed her abilities with
several of the top four accounting fi rms in the
US and Canada, including Ernst Young.
4Demystifying the Expatriate Assignment Process
- December 6, 2011
- Portland Relocation Council Meeting
5Agenda
- Outbound Expatriates
- How to determine cost differentials
- Elements of the assignment contract
- Estimating the overall cost to the company
- How to Pay
- Certificates of Coverage
- Tax equalization
6Agenda (Contd.)
- Inbound Expatriates
- Local hire vs. temporary assignee
- Split payroll considerations
- Tax implications of various immigration visas
- International Tax Updates
7Outbound Expatriates
8Cost Differentials
- Most temporary assignments abroad attempt to keep
the assignee economically neutral. - Measure four categories of cost differentials
- Housing
- Cost of living
- Transportation
- Income taxes
9Cost Differentials (Contd.)
- Helpful if you can obtain independent data for
the first 3 categories - There are specialized cost information providers
that can supply this for you.
10Elements of the Assignment Contract
- Who is the employer company?
- Is the employee on loan to host location?
- Assignment length can have tax implications. Key
cut-offs - 6 months
- 1 year
- 5 years
11- Keep base salary pure
- Denote allowances separately
- Method of payment can make a tax difference (e.g.
housing) - Description of your tax equalization process
- Assignee agrees to hypo tax withholdings
- Tax compliance process provider
12- Assignee signs agreement that all tax advances
you make on their behalf are considered debt to
the company until settled through the tax
equalization process. - Make sure all terms are agreed before the plane
leaves.
13Cost to the Company
- Determine all potential assignment allowances and
expense reimbursements - e.g. Home leaves, HHG/flights, temporary living
(front back end), visas, look see trip,
storage, language training, schooling - Data used by tax services provider to calculate
all home host taxes plus gross-ups - Total costs can be used to obtain assignment
approvals and set up cost accruals in budget.
14Certificates of Coverage
- US expatriates on temporary assignment for their
US employer can be exempt from host country
social security, and stay in US FICA/Medicare
System. - Typically only lasts for assignments up to 5
years. - US has agreements w/ 24 countries, more pending.
- Exemption from host country social security can
be a signifcant savings for employer - Employee/employer portions, other countries
systems can be much higher amounts - Apply online https//secure.ssa.gov/apps6z/coc_db/
allforms.html
15How to Pay
- Consider offering a split payroll. Some pay in
the US, some from host location. (This will help
reduce exposure to currency fluctuations.) - Also helps to manage home country
responsibilities, such as pension contributions,
social security taxes, - Suggest assignee set up an account with an
international banker, to facilitate movement of
funds from home to host. - Note will require some manual information
gathering for payroll reporting in home and host
locations.
16Tax Equalization Policy
- Most companies have this as a companion to their
relocation policy. - Philosophy is that assignee is no better or
worse off from a tax point of view - Some companies are tempted to offer protection
instead assignee is no worse off.
17- Disadvantages
- Sets precedent
- Tax benefit hard to predict
- Benefits will differ between employees
- Impedes mobility
18Inbound Expatriates
19Local Hire
- Many employees from abroad treated as local hires
here. - US tax rates are often lower, salary grids often
higher than home country. - Concept of tax equalization does not translate
well in inpat scenarios its a US-centric
concept. - Not exempt from FICA/Medicare unless have a home
country certificate of coverage
20Tax Implications of Various Immigration Visas
- Most aliens working in the US with a non
immigration work visa are fully subject to US
income tax and FICA/Medicare tax (unless exempt
by Totalization)
21Special Rules
- J-1 Trainee
- If paid from abroad, exempt from federal/Oregon
income tax. - F-1, M-1, J-1, Q-1
- Exempt from FICA/Medicare, unless they have taken
steps to be considered resident aliens. - Includes F-1 OPT (Optical Practical Training)
- Working spouses not exempt
22International Tax Updates
- China
- Income tax rates have increased as of Sept. 1
- Social tax regime will now be applied to foreign
employees for the first time - Effective Oct. 15? Implementation?
- Netherlands
- Tax relief for expats (aka the 30 ruling) will
be harder to obtain - Specific expertise test hard to meet for younger
workers - Cross border commuters ineligible
23Updates (cont.)
- USA
- New FATCA form 8938 for 2011
- New foreign asset reporting form for individuals
- All foreign financial assets goes beyond
foreign bank account reporting - Large penalties for failure to file
24Questions?
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26Gary P. Tober Garvey Schubert Barer, Shareholder
GARY P. TOBER, a shareholder and member of Garvey
Schubert Barers tax practice group, is involved
in tax and business planning for U.S. and foreign
corporations, partnerships and individuals,
emphasizing the tax aspect of cross-border
business operations and investments transactions.
Mr. Tober regularly presents seminars on
international tax topics to certified public
accountants teaches graduate school courses in
international taxation at the Golden Gate
University speaks at seminars on international
commercial agreements chairs seminars on
international law and taxation and lectures on
international topics at various professional
education programs. He is admitted to practice
in the State of Washington. Mr. Tober earned his
B.A. at Denison University, his J.D. at the
University of Toledo Law School, and his LL.M in
Taxation, at Washington University School of
Law.
27Portland Relocation CouncilEmerging
International Relocation ProgramIssues, Risks
and Best Practice
- December 6, 2011
- Gary P. Tober
- Garvey Schubert Barer
- Portland, Oregon and Seattle, Washington
28Inadvertent Corporate Risks Associated With
Foreign Relocation of Employees
- Foreign Tax Nexus
- Corporate Tax Obligations in Host Jurisdiction
- Exemption Provided by Income Tax Treaties
- Social Security Taxes
- Totalization Agreements
29Inadvertent Corporate Risks Associated With
Foreign Relocation of Employees
- Corporate Implications of Employee Tax
Obligations - Tax Filings
- U.S.
- Foreign
- Tax Withholdings
- Other
- FBAR
- Legal Liability
30Income Tax Treaties
- Business Profits - Baseline Definition
- The business profits of an enterprise of a
contracting state shall be taxable only in that
state unless the enterprise carries on business
in the other contracting state through a
permanent establishment situated therein. If the
enterprise carries on business as aforesaid, the
business profits of the enterprise may be taxed
in the other state but only so much of them as is
attributable to that permanent establishment.
31Income Tax Treaties
- Threshold Requirements is the Existence of an
Enterprise. - Almost any economic activity carried out by a
resident of a treaty country creates an
enterprise. - Business Profits Generally Means Income Derived
from any Trade or Business - No direct counterpart in U.S. domestic tax law
- Only Business Profits Attributable to a Permanent
Establishment will be Subject to Tax. - Income from active business operations
-
32Income Tax Treaties
- Permanent Establishment - Baseline Definition
- For the purposes of this Convention, the term
permanent establishment means a fixed place of
business through which the business of an
enterprise is wholly or partly carried on. - If a U.S. company lacks a permanent establishment
in the other treaty country, business profits
derived in the treaty country will not be taxed
by the treaty country.
33Income Tax Treaties
- Criteria for Permanent Establishment
- Fixed place of business through which a resident
of a treaty partner engages in industrial or
commercial activity - Facilities
- Place of management
- Branch
- Office
- Simenon v. Commr, 44 T.C. 820 (1965) Home
office maintained in U.S. by French author
resulted in P.E. under U.S.-France income tax
treaty
34Income Tax Treaties
- Factory
- Workshop
- Place of extraction of natural resources
- Building site depending upon length of project.
Required length varies from six months to two
years depending upon treaty. - Exclusions
- Storage facilities
- Goods to be processed by another enterprise
- Purchasing goods or collecting information
- Activities of a preparatory or auxiliary character
35Income Tax Treaties
- Permanent Establishment by Attribution
- Degree of authority of agents (i.e., employees
are agents of their employer) - Permanent establishment results if agent has
general authority and power to contract - If agents activities are limited to exempted
activities no permanent establishment is created - No permanent establishment if agent is broker or
commission agent and independent - Independent agent is one who is neither an
employee nor under the day-to-day control of the
principal - Handfield v. Commissioner, 23 T.C. 633 (1955)
found that U.S. distributor of postcards was
filling orders from a stock of merchandise and
thereby created a permanent establishment for a
Canadian citizen.
36Income Tax Treaties
- Non-fixed permanent establishment
- Rev. Rul. 56-165, 1956-1 C.B. 849, holds that
representatives of a French company who traveled
continuously for two years in the United States
had a permanent establishment, notwithstanding
that the corporate representatives were merely
demonstrating and taking orders for machinery.
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38Joe Willis Nike, Mobility Manager
Joe joined Nike as the Americas Mobility Manager
just last October. Prior to Nike, Joe was
shoring up his Global Mobility experience at
Broadcom where he served as the Global Mobility
Program Manager and prior to that at Sony
Pictures Entertainment as the Sr. Manager of
Global Mobility. Joes working background also
includes the MI Group, Childrens Hospital of
Orange County and British Airways. He graduated
from the University of California, Los Angeles
with a B.S in Applied Geophysics and Space
Physics.
39Global Assignment Policy Overview Joseph Willis,
CRP, GMS December 6, 2011
40Global Assignment Types
- Business Trip
- Duration lt 3 Months
- Not treated as an expatriate assignment
- Short Term Assignment
- Duration 3 12 Months
- Skill acquisition/personal development OR project
assignment with defined end date - Fewer expatriate allowances
- Developmental Assignment
- Duration 3 24 Months
- Skill acquisition/personal development/global
experience - Fewer expatriate allowances
- Long Term Assignment
- gt 12 Months
- Perform a job/career development/transfer of
skills/global experience - Traditional expatriate allowances
- Dual Career Assignment
- Both spouses are employees on assignment
- Some expatriate allowances are shared
41- Expatriate Compensation
- Balance Sheet Approach
- Transferee is kept whole compared to
stay-at-home income - Minimize impact of changing market conditions in
the Host Country, such as exchange rates, tax
rates and housing costs - Base Salary
- Employee remains on Home Country payroll
- Equal to the pay of domestic peers in comparable
jobs at home location - Transfer Premium
- Compensates for separation from home, relatives,
and friends, and the particular difficulties of
international services - Currently 12.5 of gross base salary, up to a
maximum of US 12,500 - Cost of Living Adjustment (COLA)
- Differential to offset cost of goods and services
at host location to maintain purchasing power
equal to domestic peers - COLA is paid only if cost of goods and services
at host location is greater than at home location - COLA updated quarterly on Feb 1, May 1, August 1
and Nov 1
42- Expatriate Compensation (continued)
- Hardship Allowance
- Additional compensation if working under
unusually difficult conditions - Currently, 5 - 30 of gross base salary
depending on location - Revised annually
- Housing Norm Deduction
- Employees contribution to housing cost via
payroll deduction - Equals one-half of comparable housing in Home
Country and consists of - non-equity mortgage payments and property taxes
or rent, plus normal utilities - Hypothetical Tax
- Payroll deduction roughly equivalent to
Stay-at-Home tax withholding - Calculated on annual gross base salary and other
factors which affect - Stay-at-Home Tax (such as insurance and pension
contributions) - Hypo tax is not computed on transferee allowances
43- Expatriate Compensation (continued)
- One-Time Payments
- Relocation Allowance
- One half of monthly salary
- Intended to cover miscellaneous out-of-pocket
expenses during relocation, ongoing expenses
throughout the term of the assignment and offset
incidental costs associated with the move back to
the home location. - Paid via Home Country payroll
- Spousal/Partner Allowance
- Intended for spouse/permanent partner to enhance
interests, education or career while away from
home - One lump-sum payment at the beginning of the
international assignment. - Additional payments may be made if assignment is
extended. - Paid via Home Country payroll
44Scope of Services Home Country
- Auto Loss-on-Sale or Lease Break
- Intercultural Training
- Language Training
- Immunizations
- AMEX/Expense Administration
- Will Preparation
- SOS/Travel Assistance
- Mail Forwarding
- Personal Long Distance Calls
- Employee Store Shipments
- Payroll/Compensation Administration
- Policy Counseling
- Visa/Work Permits
- Shipment/Storage of Household Goods
- Insurance (Personal Effects and Personal
Liability) - Payroll
- Tax Filing/Equalization
- Medical Benefits
- Property Management
- Temporary Housing/Car Rental
45Scope of Services Host Country
- School Search
- Dependent Education Assistance
- Local Transportation
- AMEX/Expense Administration
- Tax Equalization/Services
- Policy Counseling
- Visa/Work Permits
- Temporary Housing
- Home Finding
- Language Training
- Intercultural Training
- Personal Long Distance
46- Assignment Benefits
- Home Leave
- One home leave per year, after one year of
overseas service for employee and dependents - Up to 1,000 for car rental
- Intent of home leave is for employee to travel to
home country to maintain business and personal
connections - Employee may elect an alternate destination.
Reimbursement provided for amount equal to cost
of airfare to Home Country. - Rest and Relaxation Leave
- For employee and dependents assigned to hardship
locations - One RR trip per year while on assignment
- Transferee selects destination
- 5 working days provided for RR
- Forfeited if not used during the year and cannot
be combined with home leave
47- Assignment Benefits (continued)
- Relocation Assistance Expatriation
Repatriation - Dependent Education Assistance
- Children are eligible one year prior to the
required starting age with a minimum age of 3
years (example if required school attendance age
in the Host Country is 5 years, Nike would begin
providing education assistance at age 4) - Education assistance provided for accompanying
children through age 18 - Reimbursement provided for the following
education expenses - Tuition and/or registration fees
- Cost of school bus or daily public transportation
to and from school - Books
- Laboratory fees
48- Assignment Benefits (continued)
- Housing
- Temporary housing provided in Home and Host
Country, if needed (up to 30 days in each
location) - House-hunting trip may be provided, depending on
Host Location Policy - Housing allowance is per Host Location Policy
- Furniture, appliances, utilities are per Host
Location Policy - Transportation
- Per Host Location Policy
- Some countries provide transferee with a vehicle
to drive - Other countries provide a car and driver
- Intercultural Training
- Assistance with managing cultural adaptation and
lifestyle adjustments due to transition - Language Training
- Language lessons provided to transferee and
eligible dependents to learn the official
business language of the Host Country - Healthcare
- Global Health Plan If Home Country coverage is
not valid international, employee needs to be
moved to a Global Health Plan (Cigna
International, Aetna Global, etc.)
49 50(No Transcript)
51Jennifer Fu Banfield/Mars, Inc. Global Mobility
Immigration Manager
Zhiyan Jennifer Fu is a global mobility and
immigration manager with 8 years of program
management experience in several multinational
corporations including Nike Inc., Vestas Wind
System Americas and Banfield/Mars, Inc. Her
mobility experience covers relocation, corporate
policy alignment and process set up, immigration
and visas, international tax equalization program
and social security tax management for expats and
local to local transferees. Jennifer grew up in
China. After college with two B.A. degrees and
having worked for a couple years at Procter
Gamble, China, she came to the U.S. for graduate
school. Jennifer has a Master of International
Management degree and GPHR she has worked in
non-profit, governmental and corporate sectors in
the U.S.
52Improve Effectiveness of Global Mobility The
case of Mars Incs Corporate Mobility Program
Banfield Pet Hospitals Parent Company
53Mars, Inc. Global Mobility Mission Statement
Global mobility in Mars enables business success
and provides unique experiences to enhance the
lives of associates and their family
54Mars, Inc. Global Mobility Guiding Principles
- As a global business, international mobility
is essential for our future senior business
leaders to be most effective. - Global mobility policies should be a positive
element in helping to attract, retain and
motivate associates and therefore need to
be competitive, both internally and
externally. - Moves should contain a mutual benefit for the
business, the associate and their family.
Moves will be differentiated, based on the
business need and associate personal
development. Appropriate care and support
will be provided. - Associates who are mobile will be recognised
and provided with enhanced opportunities to
learn, grow and achieve. - Clear and timely communication will be provided
on all aspects of a move to allow all parties
to make an informed decision and to clarify
ongoing support. - The value of the global mobility programme will
be tracked and evaluated to ensure that it
delivers business value and long-term
leadership development.
- As a global business, international mobility is
essential for our future senior business leaders
to be most effective. - Communicate purposes
- Support corporate goals
- Expected impact
55 Global Mobility Framework
Career Development
Strategic
Higher
- Target associates
- High Potential associates (as per identified
development action in MDR) - Personal Performance Matrix 5,7,8,9
- Mobility Types
- Short -Term Assignment (3-12 mths)
- Long-Term Assignment(2-3 years)
- Decision-maker
- Recruiting GM (with recommendation from
Host/Home PO) - Package CostStandard package (Zones 5, 6)
Lighter package ( Z7)
- Target associates
- Top roles
- Mobility Types
- Long-Term Assignment (3-5 years)
- Permanent Relocation (gt5 yrs)
- Commuter
- Decision-maker
- Recruiting President (with recommendation from
Global Talent Director) - Package
- Enhanced package / support
Development value
Corporate VALUE Host
Associate-initiated
Professional
- Target associates
- Associate-initiated moves which meet business
need for resource at reduced cost - Mobility Types
- Permanent Relocation
- Decision-maker
- Recruiting line management
- Package Cost
- Local terms, some relocation support
- Target associates
- High Professional (as per MDR)
- Personal Performance Matrix 4, 7
- Mobility Types
- Short Term Assignment (3-12 months)
- Long-Term Assignment (c.2-3 yrs, max. 5)
- CommuterPermanent Relocation(gt5 yrs)
- Decision-maker
- Recruiting GM (with recommendation from
Host/Home PO) - Package Standard package (all Zones)
Lower
Higher
Business value
Zhiyan Jennifer Fu, Manager, Immigration Program
56Improving the Selection Process
- Quality and Fit
- Only consider candidates identified through the
Mars Management Development Review (MDR) and/or
endorsed by Home/Functional Sponsor - Require cross-cultural assessment before the
interview - Use competency-based questioning to assess
ability to adapt to a different culture - Understand any spouse/partner/family issues which
may block or undermine mobility before making
final offer
57Improving the Selection Process
- Business Sponsor (Home or Functional Manager)
- General Manager, Business Head Level
- Only endorses high potential associates (HiPo) or
subject-matter experts (HiPro) challenges other
moves! - Holds briefings with associate before assignment
(delegates for junior assignees) - Ensures a suitable role after the assignment
- Accountability in Sponsors annual objectives
58Repatriation Roles and Support
- Regular Traffic Light reports from Global
Mobility Team GMT Home People Organization and
line manager - Proactive re-entry planning (particularly in last
6 months) - Management Development Reviews (MDRs)
- Returning assignees factored into home budget
- Business trip back to Home unit in last 6 months
- Ensure re-entry welcome/debriefing / knowledge
transfer
Zhiyan Jennifer Fu, Manager, Immigration Program
59Streamlining Processes and Roles
60Streamlining Global Service Providers
- Managed by GMT in the U.S.
- Tax one provider
- Relocation Destination Services One provider
- Immigration One provider
Aligned one contact group Aligned one online tool
to collect assignee info. Aligned service cost
control and reporting Aligned one location for
history
61 Program Managing Principles
- Seek executive commitment to the policies/process
- Flexibility Documenting guidelines vs. Sticking
to policies - Clear expectations for assignees
- Verbal, written support
- Specific instructions
- Centralized exception management
- HRs strategic involvement Consult with Global
Mobility Team once an opening is known/prior to
discussions with candidates - Avoid making promises to associates
- Challenge lazy resourcing
- Avoid negotiations over the package
- Support assignees re-integration
Zhiyan Jennifer Fu, Manager, Immigration Program
10/26/2013
62Questions and Discussions
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64Delayne Romson International Expatriate
Consulting, Inc. SCRP, SGMS
- Learned mobility and immigration in a corporate
environment (Apple) - Took that education and moved to a consultant
status. Current projects at this time include - Several Corporate and DSP Provider databases -
design, develop and maintain - Consultation on current or new Corporate
International Mobility programs - several
corporate clients - Industry Consultant/Project Lead for
International or Immigration RFP design,
execution and program transition - Corporate Mobility Manager for a Corporation
managing all policy writing, process design and
global movement of all employees, including
immigration. -
65DSP Services(Destination Service Provider)
- Delayne Romson, SCRP, SGMS
- International Expatriate Consulting, Inc.
- delayne_at_ieconsult.com
66What is a DSP?
- Considered a local expert in the New Country or
location. - Provides a second opinion on housing and other
issues - Services and service descriptions will vary from
country to country. - Costs will vary from country to country
- Always charged for outside of the U.S.
- Issue Finding the best DSP in the area you are
going to!
67An External Key Provider
68KEY Documents needed
- Preview Trips (not always provided)
- Intake Form - The employee usually fills out this
DSP form that notes personal preferences - Benefits list - Employer may note specific
package benefits and housing allowance, etc. - Final Move
- Authorization to reside in the Country
- Employees work permit and dependent visas
- Local Registration could be tax, could be
province - Credit - If Company is not sponsoring housing,
car or school services or does not have a program
to assist the employee in establishing credit in
the new country, perhaps a list of recommended
documentation that could be useful from the
previous country before move takes place.
69DSP Typical Services
- Immigration In many countries the DSP can be
authorized to perform these services. - Home Finding/Home Search -
- International
- RENTAL housing search - takes EE out, reviews
contracts, knows school areas, commute times,
etc.(1-5 days). Works with Employer if LTIA
contracts need to be signed and funded. - Country may not have MLS type services
- Country/Employer may require DSP separate from
Realtor - Home Purchase
- Company rarely covers home purchase but if they
do, very specific country fees are covered. - Employee may or may not be connected to a realtor
but is on their own. - U.S.
- Renter Services charged
- Home purchase a home no charge to Employer
70DSP services (cont.)
- Orientation Services -Overview of the local area
based on work or school locations. - International always charged for services
- U.S. Some form of this could included in rental
and n/c for buyer - Settling In Services
- Application for all registrations (SSN),
utilities, etc. - Children's Education Services
- International Charged for all services
- School search based on age, special needs,
location, transportation, private or public
schools. - Usually private schools so the children can
integrate back into the Home Country system upon
return. - U.S.
- DSP sometimes includes information in welcome
packet - Further search that requires applications,
language, specific needs are always charged for.
71DSP Services (cont.)
- Language Services
- International Usually offered and paid for
employee and spouse. Children are case by case. - U.S. Sometimes offered if English is second
language (ESL). - Transportation Services Assistance with setting
up auto leasing or car and driver - International DSP has the connections. Who
pays is based on the package. - U.S. - based on travel department set up
- Driving lessons Sometimes required/needed!
- Monthly housing support hot line for assignees
(usually exec) that are in long term housing. - Other Basically anything you can think of that
you need hired to have done in the New/Host
Location
72Noted Trends
- U.S. DSP services tends to be deemed as less
valuable to incoming international. - Home Sale/Home Purchase services declining.
- Private School fees EE pays part if the
children were in a private school previously. - Cultural Information is not Cultural Training.
- U.S. tends to assume foreign national may not
need assistance here.
73Questions?
74Connect for Questions
Carol-Ann Simon, Perkins Co csimon_at_perkinsaccoun
ting.com, 503-221-7580 Gary P. Tober, Garvey
Schubert Barer GTober_at_gsblaw.com, 503-816-1415
Joseph Willis, Nike Joseph.Willis_at_nike.com,
503-671-3524 Jennifer Fu, Banfield/Mars,
Inc. jennifer.fu_at_banfield.net, 503-922-5202
Delayne Romson, International Expatriate
Consulting, Inc. delayne_at_ieconsult.com,
866-417-8293
75(No Transcript)