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Senior Manager - Tax Planning And Tax Counsel
Refer job# IXVC146398
 
Senior Manager - Tax Planning and Tax Counsel Duties: Manages the success of North American federal, state and local tax planning strategies, transfer pricing policies, and state and local tax incentives. Retains outside tax counsel or external accounting firms as needed for transfer pricing, tax audits, appeals and planning. Stays connected and informed regarding new or changing business developments that may impact the tax environment (e.g., exporting to a new foreign country, investing in a new or expanded manufacturing facility, changes in business operations, and establishment of new subsidiaries). Manage tax incentives including coordination with senior Toyota management in regard to public Toyota tax lobbying initiatives, Toyota Government Affairs and Toyota Public Affairs groups. Manage coordination of global transfer pricing efforts and strategies which require close coordination at a Toyota worldwide level, including Toyota Japan, Toyota Europe, and all Toyota North American affiliates. Examples can range from simple business proposals to changes in historical cost chargebacks between US and foreign affiliates to more complicated cross border responsibilities for minimizing foreign tax withholding obligations on inbound and outbound transactions. Closely monitors federal, state, local and international tax legislative and regulatory developments. Overall responsibility for TMNA successful completion of IRS and state examinations. Closely involved in developing and implementing TMNA tax audit plans and execution of the audit. Approve FIN48 calculations and related financial statement disclosures and assist in overall accounting for income tax (tax provision) quarterly and yearend efforts. Responsible for coordination of activities and staff development of direct reports, including Tax Audits manager with a senior tax accountant, the Federal Tax Planning and Transfer Pricing manager, and the State and Local Tax Planning manager.

Qualifications: JD degree, (D.Jur. or DJur) (Tax LL.M. preferred) and Bachelor's degree in accounting or business. CPA required. Substantial experience in large to medium size corporate tax department. Public accounting audit/tax experience and public accounting tax senior manager level experience including significant experience with accounting for income taxes, transfer pricing and international tax issues. Demonstrated strong analytical and negotiation skills. Ability to work collaboratively and independently across with all levels of the company.
 
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