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Tax Attorney
Refer job# CMGN136396
Tax Attorney The candidate will support cross-border business matters and transfer pricing issues. Will cross-Border Business ( PATAC ). Utilize Siemens internal tools and guidelines to advise Siemens U.S. business units regarding international tax implications and recommended structures for conducting business projects in countries outside the U.S. Analysis of U.S. Tax Treaties, permanent establishment issues, withholding tax issues, and local tax and transfer pricing issues. Will be advising on the best structure and tax implications of delegating employees outbound from the U.S., including shadow payroll issues. Will be reviewing contract provisions and tax provisions of contracts to ensure compliance with recommended tax structure and alignment in terms of other tax issues. Will assist with the company s efforts to increase automation of processes and controls around the provision of international project advice (drafting automatic feedbacks for the tool etc.). Extensive interface with business unit personnel at all levels to explain tax rules and advice and key aspects of, and reasons for, recommended structures. Transfer Pricing. Will advise business units regarding appropriate transfer pricing with respect to a wide range of intercompany business transactions tangibles, intangibles, services, and financial instruments. Will compile information related to inter-company transactions, including preparation of memoranda and financial data summarizing the business model, transfer pricing arrangements in place, and financial results in order to comply with transfer pricing contemporaneous documentation requirements and defend transfer pricing positions on audit. Interface with personnel at business units to explain data requests and transfer pricing rules. Will work with external service providers to prepare contemporaneous documentation in support of annual transfer pricing studies. Will work with foreign Siemens personnel to collect data or assist with the implementation of transfer pricing policies.

The candidate should have Undergraduate degree (B.A. or B.S.) in Economics, Finance or Accounting. J.D. degree (with admission to a state Bar); LLM in Tax. 5 plus years of combined legal/public accounting/ private industry experience in a tax related environment. Including practical experience working with U.S. transfer pricing rules. Including practical experience providing tax advice in cross-border business situations. Strong tax research skills (including some combination of CCH, RIA, and BNA). Should have proficiency with all Microsoft Office products (Excel, Word, PowerPoint);Self-starter and team-player with strong oral and written communication, organizational (multi-tasking), and interpersonal skills. Supplemental Desired Skills. Should have knowledge of tax accounting (ex., CPA, undergraduate accounting degree or accounting experience). Experience in dealing with multinational companies.
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