Assistant Director, Tax Planning

Sony Corporation of America, located in New York, NY, is the U.S. headquarters of Sony Group Corporation, based in Tokyo, Japan. Sony's principal U.S. businesses include Sony Electronics Inc., Sony Interactive Entertainment LLC, Sony Music Entertainment, Sony Music Publishing and Sony Pictures Entertainment Inc. With some 900 million Sony devices in hands and homes worldwide today, a vast array of Sony movies, television shows and music, and the PlayStation Network, Sony creates and delivers more entertainment experiences to more people than anyone else on earth. To learn more: www.sony.com/en.
 

Sony Pictures Entertainment (SPE), a subsidiary of Sony Corporation of America, based in Culver City, CA, is one of the leaders in the entertainment industry.  SPE’s motion picture, television, and home entertainment businesses continue to build their content creation and distribution capabilities, both domestically and internationally.  

POSITION SUMMARY  

Sony Corporation of America (SCA) is seeking an Assistant Director of Tax planning to join the Global Tax Office located in Culver City, CA.  This is a highly visible position within an exceptionally talented team, reporting to the Vice President of Tax as well as working closely with the Global team with offices in NYC (Headquarters), Tokyo, London and Singapore. 

This position is on a Hybrid work schedule in Culver City that prioritizes in-office collaboration and in-person business relationship development.

JOB RESPONSIBILITIES 

• Serving as the global tax matters point person for one or more US based operating divisions with foreign affiliates within the SPE group 

• Working closely with legal, finance, business development and operations personnel based in the U.S. and with the controllers of international affiliates. Will need to communicate regularly with the divisional CFO and other high-level executives 

• Working closely with Global Tax Office colleagues in New York, London, Singapore and Tokyo – both tax planning and tax compliance personnel 

• Management of IFRIC 23 Uncertain Tax Positions for divisions(s) of responsibility – analysis, advice and quarterly reporting 

• Advising on proposed acquisitions, dispositions, JVs and internal corporate restructurings worldwide, including: conducting and/or coordinating with advisors tax due diligence; ensuring tax efficient transaction structuring; reviewing and commenting on transaction documents; providing tax input to financial models; working as part of integrated team including legal, business development, finance and operations personnel and ensuring all options, issues and risks from a tax perspective are fully understood; contemporaneously documenting tax consequences of concluded transactions for tax reporting purposes 

• Advising on Film/TV Production tax matters 

• Assisting with transfer pricing management and documentation 

• Reviewing and advising on outbound and inbound license agreements and miscellaneous business/procurement agreements 

• Advising on tax consequences of international assignments 

• Advising on tax withholding and information reporting requirements 

• Working with Government Affairs group in connection with tax legislative and regulatory initiatives 

• Coordinating with tax compliance team to ensure the proper reporting of planning transactions that occur throughout the year 

• Managing foreign tax audits, working directly with foreign advisors and controllers; addressing US tax audit issues in conjunction with US tax audit colleagues 

• Special Projects – e.g., OECD Pillars 1 and 2 Implementation issues; Legal Entity Rationalization 

• Honest