Job Details

Attorney in Santa Clara, CA

Organization Type


Job Type

Non-practicing Attorney

Date Last Verified

Oct 13, 2021

Posted on

Sep 09, 2021

Years of Experience

Min 15 yrs required


Santa Clara, CA, United States
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Senior Director Transfer Pricing and Global Tax Controversy
Responsibilities: Lead the transfer pricing team, developing, and implementing a global strategic transfer pricing framework in the complex and evolving transfer pricing landscape. Be ultimately responsible for all transfer pricing positions, planning, reporting, valuations, intercompany agreements, valuations, and documentation. Be ultimately responsible for all foreign income tax controversy matters on a global basis. Manage the budget for all external transfer pricing and foreign income tax consultants, including tax advisors and legal counsel. Strong transfer pricing and controversy technical skills, including knowledge of current/proposed tax regimes in the U.S. and globally (OECD). Team with IRS and US State & Local tax teams on transfer pricing matters that develop during these audits, including strategic use of dispute resolution tools such as APAs. Manage transfer pricing matters for acquisition integration, divestiture analysis, and IP and other valuations in connection with M&A and tax planning initiatives. Manage BEPS global reporting requirements, including Master File and Country by Country reporting. Oversee annual financial statement audit as it relates to transfer pricing with external auditor. Drive relationships with stakeholders, including (a) internal business partners in the CFO office, Corp Planning, External Reporting, Accounting, and (b) external parties such as statutory auditors, governmental revenue authorities, and industry peers. Executive communication skills, including ability to explain tax concepts and issues to non-tax stakeholders. Ability to work effectively in a fast-paced environment with competing priorities and timelines. Comfortable challenging the status quo brings fresh perspective and ideas to the table and inspires others to address big problems in new ways. Excellent people manager with a demonstrated track record of coaching and developing team members and fostering an inclusive work environment. Develop strong relationships with the business partners and establish yourself as the leader of the transfer pricing and non-US audit functions. Develop a plan for the modernization of the transfer pricing reporting for the future. Build out a team for the future by assessing the needs and potential gaps currently and build the road map for the future. Develop a plan for OECD pillar one and pillar two and how to optimize transfer pricing with the new guidelines in mind. Understand Intel's risk associated with the IRS CAP audits and begin to plan for how to address the risk areas in the future.

Qualification and Experience

Qualifications: 15 years of relevant experience focused on transfer pricing and/or controversy from a combination of a large public accounting firm and in-house experience with an MNC. Bachelor's or Advanced Degree in Economics, Finance, or similar field. A Master's Degree in Taxation or a Juris Doctor is preferred.

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