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General Counsel
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provided
exceptional
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immediately.

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

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Counsel Jobs > Senior Tax Counsel, Transfer Pricing Job in Illinois > Senior Tax Counsel, Transfer Pricing

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Senior Tax Counsel, Transfer Pricing

Refer job# YKYZ150091

Senior Tax Counsel, Transfer Pricing Responsibilities: Serve as the primary Corporate Tax resource on all technical transfer pricing matters and the drafting of intercompany agreements, working closely with other Corporate Tax team members, Legal, and the business teams. This also includes advising on transfer pricing documentation requirements and strategy to ensure transfer pricing matters are OECD/BEPS compliant. Oversee the operational aspects of Baxter's transfer pricing structure, which includes the setting of transfer prices for existing product flows, new products and new markets. Oversee the post-acquisition integration of news products/markets acquired through M&A transactions. Identify, evaluate and monitor the Base Erosion & Anti-abuse Tax (BEAT) consequences of intercompany service charges into the US, including advising the business teams on the BEAT consequences of offshoring activities that benefit the US. Develop a strong technical understanding of Baxter's IP ownership structure and mechanics of its cost sharing arrangement with Baxter affiliates. Analyzing Baxter's principal entity to ensure it has the requisite substance from a substantial contribution and BEPS perspective. Provide input on IRS audit matters that relate to transfer pricing strategies previously implemented. Analyze US, foreign and OECD legislation/initiatives to determine the impact on the Company's global transfer pricing position. Close interaction with non-tax personnel, including Treasury, Finance, Operations, and Legal. Develop the leadership and technical skills of underlying team members. Requirements: JD required; Accounting undergraduate degree and CPA certification highly preferred. 15+ years experience with a heavy emphasis on transfer pricing. Strong technical understanding of IRC Section 482 and the OECD BEPS final reports. Ability to recognize potential financial statement implications of transactions undertaken. Proven track record of working close with various groups within a corporate structure including: Treasury, Finance, Operations, Legal, etc. Strong track record of problem solving, strategic/creative thinking and superior business communication skills. Exceptional business communication skills with ability to effectively relate tax issues to non-tax personnel; strong consensus builder and team player; especially skilled at communicating with upper management on a range of broad business plans. Established relationships with international tax advisors (public accounting and law firms) around the world.

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