Global Tax Controversary & Transfer Pricing

Responsibilities, authorities and accountabilities

Tax Controversy:

• Global Audit Management: Lead the management of IRS and foreign tax audits, serving as the primary point of contact for all tax controversy matters globally.
• Risk Management: Develop and implement a comprehensive tax risk management strategy to proactively address potential tax risks and ensure audit readiness.
• Dispute Resolution: Collaborate with external advisors and internal teams to formulate defense strategies for significant tax positions, engaging with tax authorities to resolve disputes efficiently.
• Documentation: Oversee the preparation and review of responses to tax audit findings, ensuring the consistency of technical positions across jurisdictions.
• Tax Compliance: Ensure proper management of Uncertain Tax Positions (UTP) and oversee the preparation of required disclosures.
• Relationship Building: Maintain strong relationships with tax authorities, external advisors, and internal stakeholders to foster collaboration and effective communication during audits and controversies.
• Audit Systems: Implement and manage a tax audit and controversy management system to track global disputes, monitor risks, and streamline responses.
• Training: Educate and train internal teams on tax controversy and audit processes, best practices, and evolving tax regulations.

Transfer Pricing:

• Strategic Development: Formulate and implement global transfer pricing strategies and policies to align with the company's overall tax and business objectives.
• Advisory: Provide expert advice to business units on supply chain tax planning, intercompany service arrangements, and the pricing of intercompany transactions.
• Documentation & Compliance: Ensure robust maintenance of transfer pricing documentation, including reviewing benchmarks, comparables, and arm's length ranges, in compliance with local and international tax regulations.
• Advance Pricing Agreements (APAs): Lead APA negotiations and Mutual Agreement Procedures (MAP) to resolve cross-border disputes and prevent double taxation.
• Collaboration: Work closely with supply chain, manufacturing, and finance teams to ensure compliance with transfer pricing policies and processes across the global organization.
• Controversy Support: Assist in the resolution of transfer pricing disputes globally, working with local teams and external advisors to manage controversy related to both US and non-US jurisdictions.
• Intercompany Agreements: Oversee the maintenance of intercompany agreements to support transfer pricing positions and ensure regulatory alignment.
• Monitoring & Adjustments: Supervise the computation and documentation of legal entity transfer pricing true-ups and arm's length returns.

Required Qualifications

• Bachelor's degree in Accounting, Tax, or a related field. CPA or equivalent qualification preferred.

• Minimum 10+ years of experience in transfer pricing, tax controversy, and international tax, preferably in a multinational corporation or a Big 4 accounting firm.

• Expertise in global tax laws, transfer pricing regulations, APAs, and MAP processes.

Desired Characteristics

• Strong analytical, negotiation, and dispute resolution skills.
• Proven ability to manage complex audits and interact with tax authorities across multiple jurisdictions.
• Strong leadership, communication, and cross-functional collaboration skills.
• Ability to address complex tax issues creatively and proactively.
• Ability to remain updated on changes in global tax laws and trends affecting transfer pricing and controversy management.

You will be eligible to participate in Company-sponsored benefit programs, including health & welfare programs and the Thrift Plan (401k). You will have a choice of coverage options that best suit your needs. Coverage options and contribution amounts are related to your benefit elections, base salary level, and specific requirements of each of these plans.

This position is eligible for our comprehensive and competitive benefits package, which can be found here, and is further eligible for additional forms of compensation such as bonuses subject to the terms of the applicable benefit plans or policies.