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General Counsel
Consulting
provided
exceptional
service in helping
my organization
recruit for a hard
to fill position.
They did extensive
work on the front
end to understand
our needs and
our culture and
began referring
highly qualified
candidates almost
immediately.

Melinda Burrows
Deputy General Counsel
- Litigation and
Compliance, Progress
Energy Service Company
LLC

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Counsel Jobs > Tax Counsel - Senior Director Tax Controversy Job in Ohio > Tax Counsel - Senior Director Tax Controversy

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YOUR WINDOW TO A WORLD OF OPPORTUNITIES

Tax Counsel - Senior Director Tax Controversy

Refer job# TCWV141873

Tax Counsel - Senior Director Tax Controversy The candidate is responsible to review all targeted areas of tax audits worldwide. Provide legal support for Tax Appeals worldwide, including evaluation of hazards of litigation and negotiation of settlements. Provide support for all tax litigation globally, including proactive management of the evidentiary aspects of the case, risk evaluation, and participation in field visits by tax authorities. Review all major tax planning and implementation strategies, including identification and evaluation of potential trial experts at the beginning of the project and review of documentation supporting execution and technical positions. Answerable for legal review of tax accounting for uncertain tax positions and evaluations of tax reserves, including input into public filing disclosures. Evaluate transfer pricing risk worldwide and manage the evidentiary aspects of transfer pricing documentation, including master file, country-by-country report and local file reports. Develop and manage the transfer pricing controversy team worldwide. Liaise quarterly with the Law department on all tax related legal matters. Engage and manage external tax counsel and expert witnesses to defend tax positions in audit, administrative appeals and litigation processes. Ensure alignment with of transfer pricing positions globally in order to successfully defend and provide consistency in technical analysis/position. The candidate must have a Juris Doctor Degree (J.D.) from an accredited institution. Minimum 10 years of legal experience in tax controversy at a major law firm or Fortune 100 company is needed. Must be legally authorized to work in the United States without requiring company sponsorship. LLM Tax is preferred. Extensive knowledge of transfer pricing and valuation from a litigation perspective is needed. Demonstrated project management skills are must. Ability to prioritize and manage multiple projects at the same time, while adhering to strict time deadlines is required. Excellent interpersonal and relationship building skills, including both oral and written communication skills are needed. Ability to mentor and teach transfer pricing controversy team on global technical issues and trends is required. Enthusiasm to learn, including the ability to research and master a broad array of complex transfer pricing technical topics is necessary.

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