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Manager, Tax Counsel Transfer Pricing
Refer job# TZOA146873
Manager, Tax Counsel Transfer Pricing The candidate will support Tax Counsel, Transfer Pricing, focus is on tax planning and tax risk management for the Companys transfer pricing matters worldwide. Proactively managing transfer pricing risk by negotiating inter-governmental advance pricing agreements ( APAs ) and participating in other governmental programs designed to proactively address transfer pricing issues; providing advice in connection with transfer pricing audits, appeals and litigation to ensure timely and efficient resolution; drafting transfer pricing related governmental submissions; supporting the Disney legal team in drafting intercompany licenses and other intercompany agreements; and providing advice and analysis with respect to the Companys transfer-pricing related tax reserves. Will support Tax Counsel - Transfer Pricing in achieving these goals. Support Tax Counsel - Transfer Pricing in proactively managing transfer pricing risk by utilizing available resources to obtain advance tax certainty, such as advance pricing agreements, tax rulings, pre-filing agreements, OECDs International Compliance Assurance Programme. Will draft governmental submissions, presentations, and responses to tax authority information requests; perform research on tax legal and procedural issues and recommend appropriate courses of action; assist with data collection and data analysis. Assist Tax Counsel - Transfer Pricing in managing transfer pricing disputes with U.S. tax authorities including data collection and drafting IDR responses; support international tax desks in connection with local country transfer pricing audits, appeals, and litigation. Assist with application and management of mutual agreement procedure ( MAP ) cases under tax treaties to address potential double taxation. Draft intercompany IP licenses, service agreements and other intercompany documentation to ensure that intercompany transactions are properly documented and that the intercompany compensation arrangements reflected in such documentation are consistent with the Companys transfer pricing policies. Provide research and analysis and draft documentation to support the Companys transfer pricing related ASC 740-10 (FIN 48) reserves. Will support other tax functions with regard to transfer pricing matters, e.g. tax compliance and tax planning; collaborate with stakeholders in non-tax roles such as legal, finance, accounting, and intercompany transaction support team. Advanced tax research skills using online and print sources (Lexis, BNA, CCH, ). Advanced writing skills including legal memo drafting and government submission drafting. Advanced quantitative modeling and data skills, including Excel. Familiarity with income tax accounting (ASC 740-10) and experience with performing analysis for uncertain tax positions. Ability to communicate complex concepts clearly verbally and in writing

Should have BA/BS Economics, Accounting, Business, Finance or other similar field. Law Degree and admission to a state bar (with membership in good standing). Should have 6-10 years of work experience in a tax department of a multinational corporation, or equivalent experience at a Big 4 accounting firm or law firm, focused on transfer pricing matters. With legal contract drafting, IP licenses, service agreements. Should have Valuation experience and International tax experience.
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