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Director of International Tax Planning
Reporting to the Vice President of Tax, the Director of International Tax Planning is responsible for driving the global transfer pricing effort (including transfer price planning as well as transfer price documentation and reporting), and (in coordination with the Vice President of Tax), directing global tax planning, with emphasis on the international aspects of US federal income taxes. The position will also assist the Vice President of Tax (or directly lead the effort) from time to time in respect of (i) due diligence and integration for acquisitions, (ii) implementing internal corporate restructuring transactions, and (iii) executing tax efficient cash repatriation.
About the Job:
Develop and implement global transfer pricing objectives.
Monitor business unit and entity level operating margins on a monthly basis to ensure compliance with transfer pricing policies with respect to cross-border sales.
Oversee the propriety of cross-border charges for royalties, G&A, R&D and other costs.
Direct external Advisors in the preparation of annual transfer pricing documentation to support the US federal, US state/local, and (in coordination with non-US personnel) non-US tax returns (covering Master File and Local File requirements, as applicable).
Direct the global effort to prepare and file “Country by Country” reports.
Assist in the preparation of periodic projections of US taxable income and US tax, with primary responsibility for computations with respect to all “international” rules, such as GILTI, FDII, Hybrid deductions, FTC limitation baskets, Sourcing of income and deductions, etc.
Formulation and implementation of effective and tax-efficient cross-border strategies (and tax elections) for US and non-US entities, to favorably impact the effective tax rate.
Functions as a key member of a multi-disciplinary team providing tax guidance on global M&A projects including development of tax efficient structures, contract review, and tax due diligence.
Partner with global legal, finance and other teams to assist with implementation of such transactions, and the post completion documentation and follow-up.
Review of transaction documents.
Executing tax efficient cash repatriation.
Undergraduate or post graduate degree in Accounting required.
CPA with Masters in Taxation, or law degree with emphasis in taxation preferred but not required.
At least 8 years of tax planning experience with emphasis on the international aspects of US taxation, as an employee of one or more publicly-traded US-based multinationals, or equivalent experience within a Big Four public accounting firm or a major US law firm required.
Superior communication skills, considering all modes of communication (to present matters clearly, concisely, directly and effectively).
Superior corporate income tax technical skills, including all aspects of US federal income taxation (notably the international tax aspects thereof).
Sufficient familiarity with the tax regimes in at least six non-US jurisdictions.
Ability to collaborate with others.
The possibility to work in exciting and challenging industry.
To develop you professionally and to expand your knowledge through cross-functional collaboration and training experiences.
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