Sr. Manager, International Tax & Transfer Pricing
- Ensure compliance with global transfer pricing policy and procedures via the following:
- Develop and maintain inventory of all TP transaction flows and ensuring all transaction flows have intercompany contracts in line with local country expectations
- Develop and maintain tools to compute and monitor TP charges for all transaction flows
- Manage compliance with TP documentation requirements worldwide, including scoping of countries requiring documentation, determining master file/local file approach, and methodically creating approaches to low cost documentation.
- Design and development of global monitoring tools in line with BEPS Country x Country rules
- Education and training of legal entity controllership as to TP policy and procedures
- Develop and maintain tools to compute and monitor, on a global basis, Subpart F, FTC, 956, 987/988, E&P, PTI, as well as GILTI, FDII, BEAT, etc. under theTax Reform, including support of International tax directors with specific informational needs
- Provide quantitativesupport for US informational reporting relating to foreign operations
- Provide support for federal, state and foreign taxaudits in relation to transfer pricing and international taxes
- Assist director with international portions of quarterly and annual tax provision process including US international issues and return-to-provision analysis of tax returns for in-scope entities under ASC740.
- Support director on tax planning initiatives with quantitative modeling as necessary (cost benefit, valuation, etc.)
- Provide quantitativesupport on intercompany movements of cash within capital structure, including working closely with treasury team
- Model out global revenue allocations and effective tax rate to supportinternational tax planning initiatives
Successful Candidates will possess:
? Generalized knowledge of corporate taxlaw, issues, and rules commensurate with 5+ years working in Tax/ Transfer pricing.
? Minimum of 5years of proven and progressive Transfer pricing/International taxexperience with multinational organizations. A mix of public accounting and corporate experiencepreferred.
? BA/BS in Business/Accounting/Finance
?CPA and/or MSTaxation preferred
? Working experience with Accounting for Income Taxes (ASC 740), FIN48 Uncertain Tax Positions, and Section 404 of Sarbanes Oxley is required.
? Working experience with international tax areas, such as Subpart F, Section 956 inclusions, foreign tax credit, E&P, etc.
?Experience with Oracle and Hyperion or similar systems.