Peter Moser is the Vice President of Taxes at Ciba Corporation in Tarrytown, New York where he currently oversees a U.S. tax function of a Swiss parent headquartered in Basel, Switzerland. Prior to Ciba Corporation, Peter was International Tax Counsel in the Global Consumer Bank division of Citigroup Inc. in New York, New York where he focused primarily on international tax issues.Preceding Citigroup Inc., Peter was with KPMG LLP in the San Francisco, California office where he focused on mergers and acquisitions and planning and implementation of corporate restructurings. Prior to KPMG LLP, Peter was with

Ernst & Young in the Los Angeles, California office as a Senior Associate in the International Tax Services group where he was responsible for a wide range of corporate domestic and international tax issues. Peter commenced his professional tax career as an Associate in the International Tax Services group of Deloitte & Touche in Los Angeles, California. Peter earned his Bachelor of Arts in German Studies from the University of Arizona in Tucson, Arizona. He also earned his Juris Doctorate Degree from the University of San Diego School of Law in San Diego, California. Peter is a member of the State Bar of Arizona. Peter is bilingual in English and German.

KJ- What can you tell me about Ciba Corporation? PM- Ciba Corporation is the chemical division split off of what was once Ciba - Giegy. The company decided to split the chemical and the pharmaceutical businesses into two separate companies in 1997. The company was split in to Ciba Corporation and the pharmaceutical company Novartis. Ciba Corporation is a 1.2 billion dollar subsidiary of the Swiss parent Ciba Inc. headquartered out of Basel, Switzerland. Our company serves several markets including automotive paints, protective products, home and personal care products, additives for toothpaste, sun protection products, water treatment as well as paper businesses.
KJ- What attracted you to Ciba Corporation?PM- This role was attractive because it provided me with the opportunity to work in a smaller tax department than Citigroup and manage the tax function. There are seven of us in the U.S. tax group but there are around twenty tax professionals worldwide. It was an opportunity to work for a Swiss company instead of a U.S. company and I found that interesting. I went from being the International Tax Counsel working on very specific issues in a large tax department at Citigroup, to working in a smaller tax department addressing a broad band of issues of a foreign multinational.
KJ- I think you made a very good career move.PM- I think so, too! While it was interesting working in a monster tax department like Citigroup, I wanted the opportunity to do something different. I currently have the opportunity to work on corporate legal projects as well, which makes the opportunity all the more interesting for me. I actually report to the General Counsel at Ciba Corporation with a dotted reporting line to the Tax Director in Basel, Switzerland.
KJ- You were at Citigroup for more than four years. How did your experience at Citigroup shape your professional tax career?PM- My experience at Citigroup was an excellent technical learning process. I was able to move from a Big Four accounting firm and continue to establish my technical knowledge at Citigroup. I started out in the Policy Compliance Assessment Group which was formed as a result of the Enron fallout. Citigroup wanted to be on the front line of assessing and monitoring what they were doing. They also wanted to put control processes around what they were doing. It was over and above SOX Compliance monitoring. It came out at about the same time as SOX Compliance, but Citigroup wanted to be proactive and this was a system of a voluntary compliance they put forth.
KJ- What was the next group you moved into at Citigroup? PM- I moved into the Consumer Banking Group where I stayed until I left Citigroup. The tax department of Citigroup has approximately four hundred people worldwide. It was split into three divisions that consist of an investment banking division, a consumer banking division and a wealth management division.
KJ- What was it like to work in a four hundred person tax department?PM- It was a very good time in my tax career because it offered me the ability to do a significant amount of highly technical international and domestic tax work. As a Tax Lawyer, it was a good experience to work on sophisticated technical tax issues; and then take a step in the other direction and look at the bigger picture of the business issues.
The tax department at Citigroup is much like the tax department you would experience in a Big Four firm. We had a dedicated M&A group, a dedicated international tax team, a dedicated transfer pricing group, a dedicated information and reporting group and so forth.
KJ- What else can you tell me about the tax group at Citigroup? How did you find your way around a four hundred person tax department? PM- I went into the international consumer banking division and was given the overall responsibility for two divisions within the consumer bank. This was formerly called international personal banking and was in the nonresident India banking division. Now international personal banking is what a high net worth private bank does, but on a lower level for individuals who would have five hundred thousand dollars in assets to five million dollars in assets under management. This business was primarily an international business with very little U.S. presence but we had a division in the U.S. where foreigners would come to the U.S. to do their banking and investing. We had Latin American, European and Asian customers. I would look at all of the issues involved in the business and I also looked at the non-resident India business which is a business that catered to Indian nationals that moved around the world. What I learned is that there are millions of Indian nationals that are trained in India and they subsequently move around the world to jobs in the United Kingdom, Middle East or the United States. This banking division allows the Indian nationals to conduct their banking transactions through India and any other place they may be working or located around the world. This is a very large business for Citigroup because nonresidents could obtain a mortgage for their homes through these banking channels. This was very interesting because it involved a significant amount of outbound U.S. work and a lot of transfer pricing issues. For instance, as International Tax Counsel in that capacity, my interaction with the group involved a lot of interaction with the Transfer Pricing Director to make certain that we had good policies in place and we worked on our annual documentation with the Transfer Pricing Director. Information reporting was also a significant issue for the company and I would work with the Director of Information Reporting to make the process easier.
KJ- Tell us about your experience in transition from KPMG LLP to a corporate environment. PM- The transition was fairly easy because I was able to transition from doing complex technical tax work at a Big 4 public accounting firm to complex technical tax work in a corporate tax department. My experience of moving from a large public accounting firm to a large Citigroup environment was a very good intermediary step in my tax career. I had the opportunity to take on very complex tax work and I was also able to take on two different business lines at Citigroup.
KJ- Name one important technical issue you see working with a foreign owned company?PM- I find it very interesting working for a subsidiary of a large Swiss company because we have a lot of inbound issues to keep our eyes on. One example is interest stripping. I think that, from the perspective of many companies who are in the U.S. legitimately and have foreign parents; there are plenty of studies that indicate that no one is doing anything out of line.
KJ- What makes your tax career interesting to you?

PM- What I enjoy the most are interesting business transaction and the ability to prove the importance of the tax function in the overall business management process. When you are structuring a business, it is definitely important to get input early on in the transaction in order to make the process move forward more efficiently. The opportunity to work directly with the General Counsel at Ciba Corporation has been a major asset at this company. The General Counsel is deeply involved in the transaction at this company and this makes a big difference. I really enjoy being a part of the management at Ciba Corporation.

Kathleen Jennings (KJ)
Editor, The Tax Intelligence Report
Kathleen@etsearch.com

Peter Moser
Vice President of Taxes
Ciba Corporation
Tarrytown, New York
Peter.moser@ciba.com

Irenic (i-REN-ik) adj;
promoting peace or conciliatory
Example: He exhibits an irenic management style that he utilizes with a very diverse group of professionals.