Transfer pricing documentation process, and support U.S. and foreign tax compliance professionals in reporting transfer pricing positions and structures on the annual returns
Lead the transfer pricing work relating to intellectual property, cross-border services, intercompany funding, tangible goods supply chains, and ERP system design and deployment cost recharges, as well as the application of these issues to mergers and acquisitions, joint ventures and dispositions.
Responsible for coordinating advice and strategies with other members of the global tax and customs function, including compliance functions.
Lead the development of legal arguments and management of external resources in connection with transfer pricing audits and litigation in the U.S.
Support of foreign tax managers in defending their transfer pricing positions on audit and/or litigation.
Provide training to business units and functions on key tax initiatives and policies.
Minimum of 6+ years of tax experience, of transfer pricing experience
Experience in transfer pricing databases and benchmarking.
Experience demonstrating a practical and technical understanding of the transfer pricing rules .applicable to a large multinational enterprise
Ability to identify and resolve transfer pricing issues with limited input from senior team members or third party advisors
Financial skills, including financial modeling, spreadsheet and business case analysis skills.