Douglas Nakajima is a director in Marcum's Philadelphia office and a member of the Firm's Tax & Business Services division and the International Tax Practice group. He came to Marcum in 2015 via the Firm's merger with Smart Devine, a leading full-service accounting firm in Philadelphia.
Mr. Nakajima has over 30 years of experience in federal and international tax and strategic business planning, advising a diverse client base of U.S. and multinational manufacturing, service and technology and financial services businesses. He has advised public and private clients on the tax treatment of domestic and cross-border transactions, inbound and outbound business expansion strategies, domestic and cross-border acquisitions, dispositions and reorganizations, intercompany transfer pricing analysis, documentation and audit defense, treaty interpretation, and repatriation planning. He has worked extensively with tax advisors in foreign countries to develop global structures that minimized U.S. and foreign tax exposures, and in this role, has forged effective working relationships with key professionals throughout North America, Europe, Asia and the Pacific Rim.
Mr. Nakajima's previous experience includes tax leadership positions with international, national and regional accounting firms. He also served as tax counsel to a Fortune 500 corporation, where he was responsible for the restructuring of the company following its acquisition of a foreign-owned U.S. competitor. Mr. Nakajima is an attorney admitted to practice in Pennsylvania.
- IGAF Worldwide, North America, Board of Directors
- Philadelphia Tax Conference, Inc., Board of Directors
- White Horse Village, Inc., Board of Directors
- Chicago Tax Club
- IGAF Worldwide North American and European Group Tax Conferences
- Praxity North American Tax and Fiscal Conferences
- Philadelphia Tax Conference (Conference Chair, 2008-2010 and 2012)
- Tax Executives Institute
- Strafford Publications - International Tax Webinars
- "The Quest for U.S. Tax Reform: Fact or Fiction," Accounting Today, August 20, 2014
- "Global Tax Reform: Place Your BEPS," CPA Now, www.picpa.org, September 02, 2015
Analysis of cross-border capitalization & repatriation strategies
Contemporaneous transfer pricing documentation requirements
Domestic and foreign acquisition due diligence reviews
FIN 48 review and documentation of cross-border and transfer tax exposures
Foreign earnings & profits and tax basis studies
Foreign tax credit management
Management of multinational tax examinations and controversies
Management of transfer global pricing policies and methods
Multinational transaction analysis and planning
Structuring cross-border transactions for optimal tax and operating efficiency
Studies of tax processes and operating structures for optimal efficiency
Transfer Pricing Analysis
Bachelor of Arts, 1977
University of Pennsylvania
Juris Doctor, 1980; Master of Law in Taxation, 1984
Villanova University School of Law
Douglas Nakajima of Marcum LLP looks at the operation of the IRS proposed rules (REG-108060-15) that would allow related-party corporate debt to be reclassified as ....