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Tax Controversy Director New York

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Tax Controversy Director New York in US - New York

  • Full time
  • Email
  • US - New York
  • 29/10/2019
  • Report

Group Tax is a global function, with specialists currently based in the UK, US, Canada, Netherlands, Ireland and Budapest - Our strategy is to optimise the Group’s tax position through appropriate tax planning and risk management, aligned with our commercial strategy and operating structures.

Group Tax manages:

  • P&L – corporate tax £732m
  • Balance sheet – corporate tax £294m
  • deferred tax liability £2bn
  • Corporate tax cashflow - £580m
  • Indirect tax cash flow - £7bn

Group Tax is divided into the following teams; Transfer Pricing (TP) and Indirect Taxes, UK Tax, Strategy and Controversy, European Tax & Operations and North American Tax.

The North American Tax team is comprised of US tax and Canadian tax experts. The North American Tax team oversees all areas of US & Canada (NA) federal, state, and international income taxes, as well as key functions in significant indirect taxes (sales/use/commodity/property). The team is accountable for all NA income tax reporting, compliance, controversy, risk management, and planning in line with the Global Tax Policy.

Role is accountable for federal tax audit and controversy matters including audit planning and strategy, IDR responses, evaluation of proposed adjustments, and management of IRS relationship. Requisite understanding of both NA and global transactions, and other considerations that impact the federal income tax return. Role is also responsible for strategic guidance and support on significant state and local audits, and Canadian tax audits, as necessary. Utilize practices and tactics from federal audit to drive process and other improvements to state tax audits and Canadian tax audits.




NA market constitutes approximately one-third of the overall net sales and one half of operating profit for management purposes.

Market Complexity

NA market is extremely complex. Market is active in all areas of Diageo global business (supply, brand owner, demand). Legislative environment is extremely complex and evolving.

Reporting includes approx. 16 management reporting packages, multiple legal entities, and federal, state, provincial and local audits.

Leadership Responsibilities & Capabilities

  • Role is primarily responsible for developing and implementing federal tax audit strategy, and managing relationship and day-to-day interaction with on-site Internal Revenue Service auditors.
  • Assist in strategic review and responses on significant state ta x audits.
  • Suppor t Group tax strategy across federal and state taxes, international tax planning efforts and transfer pricing matters as well as M&A.
  • Responsible to display Diageo Leadership Standard and Diageo Behaviors
  • Communication and influencing of senior stakeholders across business
  • Manage resources and numerous priorities and projects

Purpose of Role

The Director Tax Controversy role has primary responsibility for day-to-day management and interaction with the on-site Internal Revenue Service auditors. The role also has a significant role in shaping and supporting U.S. federal and state tax audit strategy, as well as support to Canadian tax audits. The role is a key tax technical resource for Group Tax and key supporting role for business development, legislative and regulatory monitoring and review, Group Tax strategy projects and general tax business support.

Top Accountabilities

  • Lead tax interaction with IRS; develop and implement federal and state tax audit strategy.
  • Key supporting role in implementation of Group Tax strategy with respect to U.S. tax projects, international tax planning efforts and M&A, as well as transfer pricing matters.
  • Coordinate and manage complex projects, while influencing global cross-functional stakeholders.
  • Coordinate with U.S. and global tax compliance team on tax audits.
  • Support to U.S. state tax audits and Canadian tax audits as needed.

Qualifications and Experience Required

  • Strong federal tax technical knowledge
  • Strong legal research and writing
  • Strong financial modeling and excel skills
  • Strong tax accounting knowledge
  • 7+ years of corporate tax experience preferred
  • 3-5 years of managing Large Case IRS Audit or equivalent controversy experience
  • Both corporate and advisory experience preferred
  • Bachelor’s degree in Accounting or Finance preferred
  • JD, CPA, and/or advanced degree in taxation preferred
  • Ability to effectively lead, collaborate, and excel in a team oriented environment to optimize the company’s tax position


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