Tax Senior, Transfer Pricing

Overview

JOB DESCRIPTION The Tax Senior, Transfer Pricing is responsible for utilizing research skills and working with tax software applications to prepare simple tax returns. In this role, the Tax Senior, Transfer Pricing will be charged with gathering client information for appropriate tax filings and preparing tax accrual work papers, participating in the tax planning process and recognizing and communicating potential risks.

Job Summary The Tax Senior, Transfer Pricing is responsible for utilizing research skills and working with tax software applications to prepare simple tax returns. In this role, the Tax Senior, Transfer Pricing will be charged with gathering client information for appropriate tax filings and preparing tax accrual work papers, participating in the tax planning process and recognizing and communicating potential risks.

• Transfer Pricing Studies:
  Conducts transfer pricing studies involving the planning, documentation, audit defense and compliance stages
• Scopes, designs, and conducts the financial analysis related to intercompany transactions to include, but is not limited to an evaluation of industry and client financial data to benchmark or document appropriate intercompany pricing policies
• Completes supplemental financial analysis involving the evaluation of market penetration scenarios, calculation of the value of intangible property, and the analysis of financial transactions (e.g., loan analysis, guarantees, insurance transactions)
• Plans, schedules and executes transfer pricing analyses under the direction of STS Senior Director or STS Manager
• Manages deadlines and data due dates for assigned projects
• Utilizes standard databases to gather company information (e.g., Compustat, Amadeus, ktMINE, Edgar, 10-K Wizard, Bloomberg, Lexis-Nexis, etc.)
• Prepares project reports to document the compliance of the client’s intercompany prices with foreign and domestic tax regulations and presents consulting advice summarizing the approach, research, quantitative analysis, and the results of the final analysis
• Participates in scoping calls related to proposals and prepares draft proposals and engagement letters at the direction of STS Senior Director or STS Manager
• Prepares presentations for current clients that convey the results of analyses and recommendations going-forward or providing a review of the service capabilities of the practice for potential clients
• Participates in client interviews to gather information to understand the factors affecting intercompany transactions within a group of related companies, including but not limited to examples such as corporate structure, division of functional responsibilities, distribution of risks, value drivers for profitability, industry overview and competitive pressure, historical context, and industry information
• Manages and reviews benchmarking work completed by STS Transfer Pricing Associates

• Tax Controversy:
  Applies understanding of the audit, competent authority and APA process including statutory deadlines and requirements
• Prepares IDR responses on behalf of clients and works with clients to prepare appropriate arguments at audit, as necessary

• Tax Provision and FIN 48:
  Applies transfer pricing in the context of tax provisions and ASC 740-10;
  Drafts memos for transfer pricing ASC 740-10 analysis;
  Collaborates with Core Tax and STS Groups;
  Develops an in-depth understanding of the technical and practical issues and opportunities regarding one or more areas of taxation;
  Maintains high level of visibility in local offices and region

• Other duties as required

• Supervises the day-to-day workload of STS Transfer Pricing Associates and Interns on assigned engagements and reviews work product
• Ensures STS Transfer Pricing Associates and Interns are trained on all relevant tax software
• Provides clarification and guidance on complex concepts and tasks to colleagues and clients, as appropriate
• Delivers periodic performance feedback and completes performance evaluations for STS Transfer Pricing Associates and Interns
• Acts as mentor to STS Transfer Pricing Associates and Interns, as appropriate
• Monitors budgets and…