Al Nuñez, CPA, JD

About Al

Al Nuñez, CPA and JD, is Managing Partner at Silicon Valley Tax LLC. He spent the previous quarter century leading tax practices for Big 4 and Big 6 firms, most recently as Tax Director at Moffatt & Nichol, Managing Director and equity partner at Andersen Tax, and Partner at RSM US. He began his career at Ernst & Young in 2006.

His practice centers on the highest-complexity corners of corporate tax: multinational structuring across the United States, Europe, Asia, Latin America, and the Middle East; ASC 740 income tax provisions and Form 5471 international information reporting; transfer pricing and Section 174 R&D capitalization; and the post-TCJA regime around GILTI, FDII, BEAT, and Pillar II.

At Silicon Valley Tax he brings that Big 4 discipline to founders, public-company controllers, family offices, and closely held businesses across the Bay Area, without the overhead or turnover of a national firm.

Areas of expertise

• International tax planning and compliance (Forms 5471, 8865, 1118, 8858)
• ASC 740 income tax provision preparation and review, including uncertain tax positions
• Transfer pricing analysis, documentation, and defense
• GILTI, FDII, BEAT, and Pillar II modeling and planning
• Section 174 R&D expenditure capitalization and coordination with ASC 985
• Foreign Tax Credit planning and utilization (excess credit position, pooled elections)
• M&A tax due diligence, IPO readiness, and comfort letter reviews
• C-corporation (Form 1120), S-corporation (1120-S), and partnership (1065) compliance
• IRS controversy: audit representation, appeals, and Kovel arrangements
• Multi-state tax planning and voluntary disclosure agreements

Experience

Speaking & teaching

Al is a regular speaker at the Tax Executives Institute and the Financial Executives Institute, ASC 740 instructor at annual firm training programs, and a campus recruiter with the Association of Latino Professionals For America (ALPFA).