Executive Director, Transfer Pricing and U.S. Tax Controversy

Job Description

The Position

This role leads the global Transfer Pricing and U.S. Tax Controversy functions reporting to the Senior Vice President, Tax.  This individual will be responsible for developing and managing global transfer pricing policies, pricing, documentation, and compliance in accordance with tax laws and regulations, working closely with Tax personnel and non-Tax business personnel on any broad policy or specific issues with transfer pricing implications.

This individual will also lead our U.S. federal, state, and local Tax Controversy function and will be responsible for developing strategy and handling of cases and coordinating communications with the IRS as well as state and local tax authorities.

Broad Transfer Pricing responsibilities include: directs transfer pricing of global products throughout the supply chain; takes a proactive role in monitoring and directing all inter-company transfer pricing to achieve year-end legal entity profitability targets; works closely with Tax Accounting to ensure mix of income forecast used in the effective tax rate model is in line with forecasts used by Transfer Pricing to establish product pricing and year-end true-up adjustments; continuous improvement of processes related to tangible product price establishment and execution; pricing of intangibles, services, and financial transactions; legal entity profitability monitoring and adjustment; and all documentation.

This individual must be a self-starter who works effectively in cross-functional teams to identify and resolve transfer pricing-related issues.

This is a highly visible role within Tax and throughout the company, requiring an individual who can:

Responsibilities

• Oversee Transfer Pricing planning on a global basis and all Tax Controversy matters in the U.S.

• Analyze current and future transfer pricing strategies to help mitigate risk, optimize efficiency and facilitate future business operations.

• Develop and maintain global transfer pricing policies and US documentation.

• Provide oversight/governance for transfer pricing documentation to meet US and non-US country-specific reporting requirements.

• Communicate transfer pricing policies and support implementation across various business units and regions.

• Monitor compliance with transfer pricing policies and advise on adjustments that may be required.

• Ensure compliance with US and non-US transfer pricing rules as they may impact the broader tax considerations of the company.

• Support Finance and Operations in transfer pricing policy implementation in systems and business processes.

• Manage relationship with outside service providers.

• Assist and interface with Tax Accounting on interim and annual tax provision and reporting matters.

• Conduct financial and economic analyses and advise on intercompany transactions.

• Oversee analysis and development of IP financial valuation models.

• Research and provide advice on changes in tax law related to transfer pricing and the tax implications of proposed transactions.

• Work with Controllers to establish and manage Cost Sharing/R&D strategies, IP management, and issues related to logistics and procurement activities.

• Address service charges and management fees.

• Educate appropriate personnel in Finance and Operations regarding Transfer Pricing requirements and risks.

• Perform interviews of key employees and collaborate with HR to monitor employee locations, movements, and evolving roles and responsibilities.

• Support direction of a team of transfer pricing professionals similarly responsible for Financial Supply Chain management and transfer pricing establishment and documentation.

• Monitor legislative changes in tax laws related to transfer pricing that may impact the company's tax positions and/or compliance requirements.

• Follow developments in US and OECD tax/transfer pricing regulations and identify issues or opportunities arising from those developments.

• Lead the handling of tax audits, examinations, appeals, and potential litigation. This includes coordinating responses to inquiries from the IRS and other tax agencies, preparing documentation and negotiating settlements to minimize financial impact.

• Work with internal Tax team and local Finance teams to help establish audit defense and support for non-US locations, as needed.

Required Education, Experience and Skills

• Bachelor’s degree in economics, finance, accounting, business or a related major.

• An MBA, JD/LLM, and/or Master’s degree in relevant fi