Overview
Under general direction of the VP of Tax and in accordance with company policy and generally accepted accounting and business principles, this role ensures compliance with transfer pricing regulations globally. Responsibilities include developing strategies to minimize worldwide income tax impact and providing advice and planning support to business units when cross-border transactions are present.
Responsibilities
- Manage preparation of contemporaneous documentation and analyses supporting intercompany cross-border transactions worldwide, including (but not limited to) intellectual property rights, product sales, and services.
- Identify and implement ongoing process improvements within the global transfer pricing compliance function to improve efficiency, accuracy, and documentation of positions; coordinate with members of the Corporate Tax department and finance personnel in business units and Corporate Accounting.
- Manage completion and review of invoicing-related computations for the management of IP, including invoicing of royalties and engineering charges; ensure proper legal documentation is in place (with support of Tax Counsel).
- Complete transfer pricing studies and provide analysis to support annual charges.
- Support identification, documentation, and monitoring of uncertain tax positions under FIN48.
- Contribute to completion and review of the quarterly effective rate and any estimated US income tax payments related to transfer pricing.
- Develop U.S. and non-U.S. staff through supervision, training, and skill development work experiences.
- Contribute to successful completion of non-U.S. income tax audits that include transfer pricing issues.
- Manage collection of, and monitor completion of, transfer pricing documentation for the U.S. and other countries.
- Assist with tax planning projects involving cross-border transactions (e.g., licensing of IP and/or cross-border charges for services such as management and engineering) to minimize the income tax burden.
- Assist in responding to IRS information requests related to transfer pricing matters.
- Analyze tax impact of current or proposed transactions, including cross-border transactions, acquisitions, and divestitures.
Requirements
- Experience managing the completion of contemporaneous transfer pricing documentation and analysis supporting intercompany cross-border transactions.
- Working knowledge of global transfer pricing compliance processes and ongoing process improvement.
- Ability to manage and review invoicing-related computations tied to intellectual property (including royalties and engineering charges) and ensure appropriate legal documentation is in place.
- Experience with FIN48 uncertain tax position identification, documentation, and monitoring.
- Ability to support quarterly effective rate completion/review and estimated US income tax payments related to transfer pricing aspects.
- Demonstrated ability to contribute to non-U.S. income tax audit completion where transfer pricing is a key issue.
- Experience collecting and monitoring completion of transfer pricing documentation for the U.S. and other countries.
- Experience supporting tax planning initiatives involving cross-border transactions such as IP licensing and cross-border service charges.
- Experience assisting with responses to IRS information requests related to transfer pricing.
- Ability to analyze tax effects of transactions including cross-border transactions, acquisitions, and divestitures.
Preferred Qualifications
- Experience supporting transfer pricing studies and analysis to support annual charges.
- Prior supervision, training, and development experience for U.S. and non-U.S. staff.
- Familiarity with coordination across Corporate Tax and business unit finance personnel, including Corporate Accounting.
Compensation & Benefits
Not provided.
Location
Not provided.