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Anthony Fay is a seasoned tax professional with extensive experience in international tax, corporate tax, and transfer pricing. He has worked with prominent firms in Hong Kong, including Jane Street, Clifford Chance, and White & Case. Fay has held various senior roles, including Head of Group Tax at AIA and Head of Risk, Asia Pacific at QBE Insurance. He has also worked as a Counsel at White & Case, where he led the Greater China Tax Practice. Fay holds a Doctor of Law (JD) from UCLA School of Law and a Bachelor of Arts (BA) in Economics from UCLA. He is proficient in English, Chinese (Mandarin), and Japanese.

Credentials

  • Attorney at Law (California)
    State Bar of California

Experience

  • Jane Street
    • Hong Kong SAR
    • Tax Specialist
      • Oct 2022 - Present
      • Hong Kong SAR

      Counsel for tax structuring, planning, and advisory for Asia capital markets and financial products transactions.

    • Counsel
      • Oct 2015 - Oct 2022
      • Hong Kong

      Counsel for tax structuring, planning, and advisory services for Asia inbound and outbound transactions across financial and non-financial industries. - Greater China tax advisory on direct and indirect taxes- M&A tax planning and tax reps, warranties and indemnities drafting and negotiation- Tax structuring and documentation for funds- FATCA and CRS tax advisory and documentation review and drafting- Support insurers in underwriting Warranty and Indemnity insurance in relation to tax- Executive compensation tax structuring and documentation

  • QBE Insurance
    • Hong Kong
    • Head of Risk, Asia Pacific
      • Apr 2014 - Oct 2015
      • Hong Kong

      Implementation of Asia operational, financial and reputational risk management framework.

  • AIA
    • Hong Kong
    • Head of Group Tax
      • Oct 2007 - Apr 2014
      • Hong Kong

      Led tax planning and structuring for all corporate transactions, including capital markets and M&A opportunities, in Asia Pacific; managed Group tax reporting, planning, compliance and controversy function.

  • White & Case
    • Beijing, Shanghai, Tokyo
    • Counsel
      • Aug 2001 - Sep 2007
      • Beijing, Shanghai, Tokyo

      Managed and led Greater China Tax Practice covering China and Hong Kong; advised on all aspects of taxation of foreign direct investments into China for financial and non-financial industries, especially in the areas of real estate investments, M&A transactions, and tax-efficient profit repatriation strategies; advised on U.S. and Japan international tax planning and transfer pricing.

    • Tax Associate
      • Apr 1999 - Aug 2001
      • Los Angeles, CA

      Researched and prepared legal memoranda on US federal and state tax laws; prepared and filed U.S. Tax Court Petitions and requested administrative rulings from California state and local tax authorities.

  • Ernst & Young
    • Los Angeles, CA
    • Senior Tax Consultant
      • Oct 1997 - Apr 1999
      • Los Angeles, CA

      Advised clients on inbound and outbound US federal income tax issues including “check-the-box” planning, foreign tax credit planning and utilization of treaty networks; reviewed and analyzed financial statement and income tax return information, including Form 5471’s and calculated foreign earnings and profits and Subpart F income.

Education

  • 1994 - 1997
    UCLA School of Law
    Doctor of Law (JD)
  • 1990 - 1994
    UCLA
    Bachelor of Arts (BA), Economics

Suggested Services

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Industry Focus. “Financial Services”

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