Associate Director, Tax & Transfer Pricing at Perrigo in Allegan, MI

Perrigo is looking to add an Associate Director of Tax & Transfer pricing to its global Tax team located in Allegan, MI. The Associate Director, Tax and Transfer Pricing is a key role in the Tax Organization reporting to the Senior Director, Tax and Transfer Pricing. This individual will be accountable for managing global transfer pricing policies, pricing, documentation and compliance in accordance with tax laws and regulations. The role also works closely with Tax Planning personnel and non-tax business personnel on any broad policy or specific issues with transfer pricing implications, including FDII and BEAT planning issues.

Responsibilities:

• Analyze current and future transfer pricing strategies to help mitigate risk, optimize efficiency and facilitate future business operations.
• Assist with the development and maintenance of global transfer pricing policies and documentation.
• Model tax impacts of proposed intercompany transactions, including IP (Intellectual Property) licensing.
• Assist and interface with Tax Accounting on effective tax rate forecasts, and interim and annual tax provision and reporting matters.
• Conduct financial and economic analyses and advise on intercompany transactions.
• Collaborate with the Senior Director, Tax Controversy on transfer pricing audits. Work with Global tax department and local finance teams in the development of audit strategy, preparation of defense files and audit responses.
• Work with Controllers and Global tax colleagues to establish and manage Cost Sharing/R&D strategies, IP management, and issues related to logistics and procurement activities. Assist with the maintenance of internal records and documentation supporting IP funding and ownership, including drafting relevant intercompany agreements.
• Review and quantification of audit risk for FIN 48 purposes.
• Support and/or lead global and regional projects to enhance Perrigo’s transfer pricing framework and intercompany transactions including global re-vamp of services in terms of transfer pricing methodology, operational execution and ongoing compliance.
• Develop and maintain strong relationships with key stakeholders across the organization.
• Lead Quarterly Business/Transfer Pricing review cadence with a view to ensuring proper execution of transfer pricing policies and identification of business changes impacting transfer pricing compliance within the Group.
• Assist in undertaking Group wide functional analysis and documentation.
• Engage with 3rd party providers to ensure robust, consistent, compliant and sustainable transfer pricing documentation.
• Support Legal Entity Integration and restructuring activities, including coordination, preparation and review of relevant valuations.
• Liaise with Business Operations in the region to ensure compliant product pricing and application of appropriate markups.
• Monitor legislative changes in tax laws related to transfer pricing that may impact the company's tax positions and/or compliance requirements and assist with modeling the impacts of such proposals and changes.
• Demonstrate strong communication skills with the ability to translate complex tax matters into language that can be understood and factored into overall business decisions by management.
• Assist in evaluating US and global tax impacts of new transactions, acquisitions and divestitures.
• Develop and mentor individuals as necessary.
• Ability to interact collaboratively across the finance organization, with external advisors and auditors.
• Demonstrate leadership skills and ability to influence at all levels.

Required Experience:

• Broad understanding of US federal income tax rules and US GAAP Financial Reporting, as well as global transfer pricing regulations
• Ability to write technical memos and prepare presentations that are clear and persuasive, for both tax professionals and business executives
• Experience in identifying, analyzing and conveying complicated transfer pricing and tax issues in terms of the impact on business operations and results. Working knowledge of international tax aspects of the TCJA, such as GILTI and BEAT.
• Working knowledge of ASC740 and tax compliance reporting requirements as applied to business and tax driven
• Superior project management and leadership experience involving large multi-functional teams; ability to plan, monitor, and manage to deadlines. 5+ years of managing and developing staff preferred.
• Good interpersonal skills, including ability and desire to communicate, collaborate, and coordinate with others throughout Perrigo Tax, Finance, and Business Units.
• Experience thriving in a fast paced, highly demanding work environment with multiple evolving priorities.
• Independent problem solving, strategic & creative thinking and interpersonal skills.
• These skills are typically acquired through the completion of a Bachelor's Degree within a related field; combined with 10+ years of relevant work experience.
• MBA, M.A. or MST preferred.
• Big 4 Accounting Firm, Large Law Firm, or Large Corporation Tax Department experience preferred.