— . Work with internal personnel and external advisors on researching, developing, implementing, and documenting corporate restructuring and global tax planning strategies to optimize the Company's global effective tax rate and cash taxes.
— . Identify and evaluate cash repatriation/financing opportunities, including working closely with the Treasury department to understand US and other global cash needs.
— . Lead the management of IRS audits of the Company's income tax returns and oversee/review developments on the income tax audits of the Company's foreign affiliates.
— o Review or preparation of responses to IRS requests related to international and foreign tax positions
— o Collaboration with the Domestic team for preparation and oversight of responses to requests related to US domestic tax positions
— . Review critical US tax returns for foreign affiliates and transactions, including the Form 1118 and various withholding tax filings.
— . Collaborate with the Tax Accounting group to identify, review and analyze the tax accounting implications of international tax planning strategies and audit developments. Review quarterly analysis of deemed & actual inclusions as well as the foreign tax credit, APB 23 positions and various FIN 48 reserve positions arising out of US and foreign tax positions related to global transactions, as prepared by the Tax Accounting group.
— . Work with US and non-US tax personnel, on an as-needed basis, on foreign tax matters and special projects.
— . Participation in review of various transfer pricing matters via collaboration with internal Transfer Pricing resources.
— . Identify recommendations, as well as implement continuous improvements, regarding global audit and documentation policies and related tax accounting processes/systems for international tax positions to ensure proper controls and efficiencies.
— . Minimum 6+ years tax experience with large multi-national, international tax planning and compliance with extensive knowledge regarding foreign tax credit, Subpart F, 5471s and 1118, and the US tax implications of foreign currency transactions; exposure to tax accounting issues regarding international operations.
— . Effective communication skills to interact effectively with tax and non-tax personnel; strong project manager, team player.
— . Accounting undergraduate degree and CPA certification required; MST degree, or equivalent, is highly desired.
— Annual travel requirement: Minimal domestic and international travel, on an as needed basis, 5% - 10%.
— This position will focus on international tax planning and US & foreign tax audits of global tax positions for all divisions of the Company which includes approximately 50 foreign entities. This role will interface with key Global Tax Department personnel as well as the finance, treasury, operations, and legal departments.