About this role
Reporting to the International Senior Tax Manager, this position will support all aspects of US outbound international and transfer pricing matters of a US-based technology multinational Corporation.
Assist with various US International tax calculations and analyses including E&P, FTC positions, Subpart-F, GILTI, FDII, and BEAT for planning, quarterly & year end provision and compliance purposesManaging international components of the co-sourced US tax compliance process, including all related computations, forms, disclosures & schedules.Assist with modelling and analyzing scenarios to assess and advise on potential tax implications from operational changes, restructuring initiatives, and tax law changes.Project management on critical tax restructuring projects such as IP onshoring and buy-sell conversion.Review contracts and collaborate with legal and the business to ensure contracts contain key terms consistent with global tax structureAssist in international tax planning, including subpart F minimization, repatriation, intercompany funding, foreign tax credit and foreign source income planning, international M&A, Federal legislative planning, and non-US ETR planning. Identifying and developing opportunities for ETR, cash, go-to-market and supply-chain efficienciesPartnering with regional finance and tax personnel to review and provide feedback as needed on foreign reporting packages and tax provisions at quarter-end and year-end, as well as provision-to-return true-up analysis.Manage post-acquisition restructuring of target’s IP and legal entity footprintMonitoring and assessing proposed tax legislation in the U.S. and significant foreign jurisdictions and assess impact to Company and for potential opportunities, exposures, and mitigating strategies.Review Permanent Establishment risk identifiers and metrics and implementation of strategies to mitigate PE risk.Supporting transfer pricing planning, maintenance, calculations, documentation and potential for automation for intercompany transactions such as royalty, cost sharing, management fee, and profitability of foreign cost+ and limited risk distributor subsidiaries. This is a co-sourced relationship with outside service providers.Supporting & defending US international audit issues and foreign tax audits.Research and advise business divisions and local finance team on global withholding tax requirements.Supporting tax technology, automation, and process improvement initiatives as it relates to international tax matters and computations. BA/BS in accounting; Masters in Taxation and/or CPA and/or JD preferredMinimum 6+ years overall experience with US multinational tax operationsPreference for combination of public company industry and Big 4 backgroundStrong technical experience in US international tax. US GAAP income tax accounting experience with international tax matters preferred.Results-driven with a high level of initiative, urgency, accountability and integrityStrong excel skills or an enthusiasm to strengthen such skills for efficienciesStrong project management and organizational skills to managing projects involving external advisors, auditors, regional finance, and business teams. Partnering and developing relationships with various groups to ensure cross-functional alignment throughout the organization.Strong verbal and written communication skills and capable of explaining work products and calculations to non-tax cross functional teams and business leaders.Proven track record to meet various deadlines associated with day-to-day responsibilities alongside special project-work