Senior International Tax Counsel, Tax and Customs
The candidate will be a member of company's global tax planning team and will have specific responsibility for tax planning for an assigned part of the Strategic Planning Group, with a focus on international tax planning. Responsibilities will include cross border capital and legal entity structuring, mergers and acquisitions, joint ventures and dispositions. Responsibilities will also include the review and handling of US tax planning issues for the ongoing operations of global business. This will include Subpart F and foreign tax credit planning, trading patterns and finance, transfer pricing, and tax controversies and audits. Will also be responsible for coordinating advice and strategies with other members of the global tax and customs function, including compliance functions, as well as the US GAAP reporting of the advice and strategies with Corporate Financial Reporting group. Provide tax advice to business units and functions with an emphasis on company's operations outside of the US Tax planning entails development, issue identification, development of alternative solutions, recommendation to business unit and functions, assistance with implementation and if necessary post-implementation review. Provide tax advice to other members of the Tax Planning Group. Assist with development of legal arguments and management of external resources in connection with audit and litigation in the US. Provide ad hoc and continuous training to business units and functions on key tax initiatives and policies. Assist International and Federal group with complex US reporting issues.
The candidate should have a J.D. degree. Graduation with honors from top 25 law school preferred. MBA or other degree in quantitative area will be highly desired (e.g., economics or finance). Must have 7+ years of tax planning experience including 4+ years with a major law firm or Big Four public accounting firm. Experience must translate into an in-depth understanding of International and US taxation of domestic transactions and US taxation of mergers and acquisitions as well as the ability to model and optimize outcomes. Should have ability to identify and resolve issues associated with complex international transaction without assistance of a third party. Must have writing skills acquired through legal training as well as work on IRS rulings, appeals and/or litigation. Experience managing relationships with law firms and accounting firms needed. Should be willing and able to continue to learn the developing areas of tax laws. Additional experience in taxation of partnerships, financial products, income tax accounting and tax procedure / reporting preferred.
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