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International Attorney / Tax Attorney in San Diego, CA

ViaSat, Inc. May 03,2017 Apr 27,2017 Location San Diego CA
This job is expired...

In-House

Attorney

International Law

Litigation - Whistleblower - CFTC

Tax

Min 10 yrs required

Profile

Director of Transfer Pricing Tax The candidate will act as a key member of senior staff for development and implementation of corporate tax transfer pricing business strategies. Lead highly sophisticated global international tax planning projects, identifying highly complex, multi-jurisdictional tax issues and opportunities. Critical senior management team member and advisor for proposed transactions, synthesizing multi-jurisdictional advice into a comprehensive solution based on inputs from outside advisors and knowledge of the organization, as well as impacts of international income tax legislative developments. Identify, research, and implement tax planning strategies related to the repatriation of foreign earnings, minimization of Subpart F income, and transfer price planning with overall goal of reducing the Company's effective tax rate. Provide expertise in transfer pricing, tax treaties & anti-avoidance; assist with dispute resolution, competent authority proceedings and advance pricing agreement negotiations. Manage the international and U.S. compliance reporting related to foreign entities to ensure all transfer pricing reporting obligations are satisfied accurately and timely implementation of BEPS. Lead the tax accounting provision process for transfer pricing on international operations under ASC 740 in accordance with a COSO Framework or Sarbanes-Oxley 404 on a quarterly basis, including the international income tax transfer pricing contingencies (Fin 48). Manage the international transfer pricing tax component of the Company's audits. Review scope of audit with agents, manage IDR responses, identify issues and resolutions favorable to the company, and negotiate with agents to resolve issues. Manage foreign tax audits, especially on issues related to cross-border transactions. Determine areas of tax exposure and manage risks associated with these tax audits, keeping senior management apprised of potential liability, and ensuring that reserves are adequate. Coordinate with business units, Treasury, Law, Accounting, Supply Chain and other corporate functions along with communication with executives at all levels at the company. 10 + years of experience in large corporate tax environment, which may be in industry, large tax consulting firm or Big 4 required. Must include International tax involvement. Extensive knowledge of corporate tax law and accounting principles required. International tax planning experience and strong understanding of US GAAP accounting rules and pronouncements preferred. Proficient in tax compliance processes and technology US Inbound tax experience and strong understanding of international (non-US) tax systems and transfer pricing principles required. Fundamental understanding of Federal income tax law preferred. Bachelors Degree in Accounting or Finance required. Masters of Taxation or JD / CPA preferred.

Additional info

Job ID: 13843BR

Company info