Tax Senior Manager, Transfer Pricing

Job Summary:

The Tax Senior Manager, Transfer Pricing is responsible for advising clients of the transfer pricing implications relating to their business objectives, recommending alternate courses of action, as well as identifying different methods of complying with transfer pricing regulations. In this role, the Tax Senior Manager, Transfer Pricing will be charged with marketing, networking and business development within their area of experience and specialization and recognizing potential changes in tax policy and applying new policies to tax compliance.

Job Duties:

• Research
  • Completes financial analysis related to intercompany transactions to include an evaluation of industry data and financial data provided by the client to assist in the documentation of appropriate intercompany pricing policies
  • Identifies when research is appropriate and frames issues to be researched
• Tax Compliance
  • Participates in determining the scope of transfer pricing projects, establishing project budgets and timelines and drafting and presentation of presentations to prospective clients
  • Administers the completion of the economic analysis and composes the final report
  • Ensures clients are compliant with transfer pricing requirements and proposes a year-end transfer pricing review, if applicable
  • Assists in determining appropriate transfer pricing methods under IRS regulations and analogous rules under the OECD Transfer Pricing Guidelines
  • Ensure tax engagement letters are adopted prior to engagement work commencing
  • Conducts detailed review of facts relating to transfer pricing and data and identifies basic, complex and advanced issues through the engagement
  • Manages engagement to achieve engagement metrics
  • Completes the project planning process and scheduling 
• Tax Controversy
  • Represents clients before any tax authority on contested issues, as appropriate, and with assistance and guidance from senior STS Transfer Pricing professionals
• Transfer Pricing Consulting and Documentation Services
  • Develops, recommends, and implements appropriate transfer pricing methods (by type of transaction) to specific situations 
  • Prepares planning/documentation reports 
  • Applies transfer pricing regulations relevant to particular types of transactions when analyzing client business and financial data and identifies any issues
  • Analyzes the applicability and implications of new regulations and reports those findings to STS Senior Director and/or Tax Principal
  • Recognizes need to utilize other expert resources, internal and external, to assist with engagements, as needed
  • Identifies opportunities for additional consulting specialties and federal tax cross selling opportunities and presents possibilities to appropriate members of senior management
  • Analyzes client situation and tax goals and provides transfer pricing advice to maximize the benefits the client
• Tax Provision and FIN 48
  • Employs general principles in tax accounting and relevance of transfer pricing in tax provisions
  • Applies transfer pricing in the context of tax provisions and FIN 48
  • Reviews tax provisions related to transfer pricing
  • Partners with Assurance professionals to plan tax accrual reviews related to transfer pricing
• Practice, Staff and Business Development
  • Identifies opportunities and prepares and delivers presentations to pitch service capabilities to clients and potential clients
  • Prepares proposals, statement of work and engagement letters
  • Researches a variety of tax topics related to transfer pricing
  • Works on teams that summarize and report on recent transfer pricing developments
  • Drafts tax alerts that are used to communicate recent developments to an external audience
  • Creates slides for use in presentations to internal and external audiences
  • Prepares training materials and presents on topics of interest to internal audiences
  • Works on special projects to develop the practice, create efficiencies or improve process
• Tax Related Software
  •  Uses tax research databases and other tax-related software in the com