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In-House
Attorney
Tax - General
Min 15 yrs required
Senior Director, Tax Counsel The candidate will devise sound strategies to minimize cash taxes and the effective book tax rate including foreign tax credits, Subpart F, transfer pricing, dividend repatriation strategies, hybrids, withholding taxes, and foreign currency exchange issues. Manage global tax audits and controversies, coordinating with the VP Global Tax Reporting on all tax exposures; provide research and support for tax audit and litigation issues and manage all global tax audits for optimal outcomes providing proper documentation for support. Monitor and provide analysis of legislative and regulatory developments and interact with regulatory bodies with respect to tax matters; evaluate potential impact of tax legislation on the company and recommend the proper course of action. Work closely with the Tax Accounting and Compliance group to provide support for company tax liability positions and FIN 48 tax reserves. Provide tax support and ensure tax optimization and compliancy for corporate treasury initiatives such as asset backed securitizations, inter-company capital structuring, tax-related debt covenant provisions, Master Leases, receivable securitizations, etc. Manage global transfer pricing issues and policies, and ensure tax compliancy and adequate documentation for all tax aspects of legal agreements including M&A, royalty, technical support, license and intercompany debt agreements. Manage and coordinate with internal and external stakeholders on all M&A activity and tax planning strategies including design, feasibility, implementation, execution, and building processes.
Qualification and Experience
The candidate should have Master’s degree in taxation (LLM); Bachelor’s degree in accounting is needed. Experience in a mix of public (Accounting or Law Firm) and extensive corporate experience managing a tax council function for a U.S. multinational public company; state and local tax planning experience is essential. Law degree JD degree. Should have 15+ years of strategic tax and large project management experience with a proven record of U.S. and non-U.S. planning initiatives that include design, feasibility, implementation, execution, and internal sustainability. Extensive knowledge and experience in research and planning in U.S. Federal and non-U.S. taxation with emphasis on tax laws and structures in European countries is needed. Must have extensive and broad M&A experience with various structures for acquisitions and divestitures; managing internal process of tax structuring check lists, legal documentation, proper recording of transactions in books and records, etc. Must have Proficiency with Microsoft Office Suite (Word, Excel, PowerPoint, and MS Project) and tax research software; ability to quickly learn and achieve proficiency in new software applications. Experience with global income tax accounting and the interaction with tax planning strategies are needed. Excellent verbal and written communication skills; able to present clean, organized, and thorough information and data appropriate for intended audience is essential. Strong global business acumen, tax research, legal documentation, and internal process management is needed.
Requisition Id: 41228
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