Sr. Manager- International Tax

 Requisition ID:          61415 Title: Sr. Manager, International Tax Division: Shareholder Relations and Taxation Location: REMOTE Salary Range:

 

Salary Minimum: 165,000.00 Salary Maximum:  235,000.00

Main Objective:

Support the tax and finance teams in the management and review of international tax matters for Arthrex, Inc. and its subsidiaries. Work within the tax group, as well as with various business teams within the company and with other members of the global finance department to maintain the company’s inter-company transfer pricing policies and compliance; US international tax reporting; and Pillar II initiatives.

 

Essential Duties and Responsibilities:

1. Maintain a deep understanding of various entities, transaction flows, risks and functions, selecting pricing models to apply and advising on the various intercompany transactions, relationships and agreements.
2. Research, identify, and document companies with similar functions, risks, and assets to serve as a basis for determining the appropriate transfer price between related party entity transactions within the organization (benchmarking analysis).
3. Proactively collaborate with various teams within the company to gather relevant information to analyze, manage, develop, draft and implement the global transfer pricing policies of the company as well as provide strategic and tactical transfer pricing guidance to internal business teams.
4. Tax audit support for transfer pricing positions and issues with domestic and foreign tax authorities and tax controversy matters, including double tax relief through Mutual Agreement Procedures.
5. Preparation of Master File and Local File transfer pricing compliance reports consistent with OECD BEPS and local country requirements. Preparation of internal documentation to substantiate the process and procedures that support the transfer pricing policies and any one-off transaction positions.
6. Coordinate and manage the work performed by outside advisers to ensure compliance with local tax requirements, returns and filings (including but not limited to corporate income, VAT, withholding, expat tax) for foreign subsidiaries.
7. Preparation of the annual US country-by-country reporting (Form 8975) to align with financial reporting of all intercompany transactions; the information returns of US persons with respect to certain foreign corporations (Form 5471) and foreign disregarded entities (Form 8858); GILTI analysis including the high-tax exclusion; FDII analysis, if required; Subpart F analysis; and, Foreign Bank Reporting.  
8. Research and/or work in conjunction with external advisors to determine if newly created foreign entities or entities from international mergers or acquisitions should elect foreign disregarded entity status or remain foreign controlled corporations; monitor entities post determination to ensure benefits of such classification are being obtained.
9. Partner with foreign subsidiaries to prepare required calculations and documentation for ASC740, Accounting for Income Taxes.
10. Monitor foreign cash reserves in order to plan for tax efficient cash repatriation.
11. Collaborate with the internal tax group, as well as finance/tax members of global subsidiaries, to address, develop, and implement the required reporting for all BEPS Pillar II requirements.

 

Incidental Duties:

The above statements describe the general nature and level of work being performed in this job. They are not intended to be an exhaustive list of all duties, and indeed additional responsibilities may be assigned, as required, by management.

 

Education and Experience:

• Bachelor’s degree required, in Economics, Finance, Accounting or related field.
• Advanced degree, such as a MA/MS or MBA and/or multinational corporation experience preferred.
• 6+ years of Transfer Pricing experience applying the US transfer pricing regulations and OECD Guidelines required. Demonstrate in-depth knowledge and experience conducting functional analysis interviews and preparing transfer pricing reports and documentation required.