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Senior Director, Regional Tax Counsel (Level O) The candidate will reports to the International Tax Director, and have responsibility for tax matters involving the company's foreign subsidiaries. Will have extensive hands on responsibilities for identifying, formulating, and recommending appropriate tax planning opportunities, and implementing compliance process initiatives. Maintain broad-based expertise of US tax laws, tax treaties, and proposed legislation relevant to determination of (i) the company's Foreign Tax Credits, (ii) the company's Foreign Tax Credit Limitation, and (iii) the US tax implications of actual and potential international transactions engaged in by the company and its foreign subsidiaries, and planning in regard thereto. Maintain general working knowledge of existing and proposed foreign tax laws of each country in the Region sufficient to provide advice to management. Analyze and interpret relevant US and international tax laws and tax treaties to minimize worldwide taxes imposed on the operations of the company and its foreign subsidiaries, including intercompany payments of royalties, regional staff charges, dividends, interest, etc. Develop and maintain a working knowledge of indirect taxes (e.g., VAT, customs, etc.) and assist in identifying and implementing strategies to reduce such taxes. Counsel US and foreign management on tax aspects of supply chain structuring, foreign acquisitions, dispositions, and reorganizations, including the structuring of new international subsidiaries or entry into new foreign manufacturing distributor arrangements. Effectively and persuasively communicate complex concepts and strategies to company-wide management and foreign advisors. Regularly interact with international management, including foreign travel, to understand current and future business objectives and structures and to develop tax strategies to assist the company in achieving those objectives and structures while minimizing the global tax expense of the company. In conjunction with Corporate Treasury, plan, analyze and recommend financing structures for capital/borrowing needs of foreign subsidiaries, and investment of excess US and foreign funds and recommend payment and timing of dividends, royalties, and interest to assure optimum tax impact on worldwide profits. In conjunction with the Law Department and International Finance, implement and maintain license, regional staff services, and other key agreements between the company and its international subsidiaries and distributors; and, direct and assist foreign subsidiaries in obtaining government approvals for payment and/or deductibility of charges under such agreements. Review and draft as necessary legal documents to accurately express the company's intent and to achieve tax minimization objectives. Actively monitor and counsel management on tax issues relating to various transfer pricing issues, including preparation and maintenance of documentation related thereto. Assist foreign subsidiaries with tax audits relating to tax deductions for related-party payments, transfer pricing matters and other significant items and in prosecuting tax appeals relating to such matters. Analyze and interpret US tax laws to assure compliance with US tax reporting requirements regarding the operations of, and the transactions conducted by, the company's foreign subsidiaries. Assist with preparation and review of the budget, fall forecast, etc., calculation of US Foreign Tax Credits and Limitation, and tax return calculations and forms (IRS Form 1118) and information returns (IRS Forms 5471, 8865, 8858, etc.), as prepared by other staff personnel. Participate in US IRS audits, including the preparation of responses to international IDR's, assessing the company's position on disputed items, and recommending whether to dispute IRS adjustments. Identify, select, and periodically review foreign tax advisors as required to achieve objectives. Maintain knowledge of accounting for income taxes, recommend and draft financial policies to properly implement accounting standards on income taxes, and provide advice to management regarding the tax accounting aspects of transactions and legislative developments. Should have a Bachelor's degree in accounting or finance (preferably a CPA), and an advanced post graduate degree (Master's of Tax, J.D.). Must have 6-8 years of intensive tax experience at a multinational corporation, major law firm, or large accounting firm, with 4+ years focused on international taxes.
Requisition Number: 5354BR
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