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Manager, Tax Counsel Transfer Pricing

Company: The Walt Disney Company (Corporate)
Location: Glendale
Posted on: January 17, 2020

Job Description:

  • 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 etc.
  • In connection with the above, 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.
  • 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.
  • 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.
  • Advanced tax research skills using online and print sources (Lexis, BNA, CCH, etc.).
  • Advanced writing skills including legal memo drafting and government submission drafting.
  • Experience with legal contract drafting, e.g. IP licenses, service agreements, etc.
  • 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.
  • Ability to manage multiple projects and priorities.
  • Valuation experience.
  • International tax experience.
  • BA/BS Economics, Accounting, Business, Finance or other similar field.
  • Law Degree and admission to a state bar (with membership in good standing). Masters in Tax and/or Accounting.CPA certification Disneys Tax Counsel group consists of tax attorneys who provide tax legal advice in connection with various aspects of the Companys day-to-day operations and contemplated transactions. This includes supporting operations of the Companys business units such as Studio, Media, Parks Experiences and Products, and Direct-to-Consumer and International. Other group responsibilities include providing tax legal advice in connection with tax audits, appeals, litigation, and transfer pricing matters, and supporting implementation of tax planning and restructuring initiatives.

    This role in particular will support Tax Counsel Transfer Pricing, whose focus is on tax planning and tax risk management for the Companys transfer pricing matters worldwide. This includes, for example, 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. This role will support Tax Counsel Transfer Pricing in achieving these goals.
    Required Education :
  • BA/BS Economics, Accounting, Business, Finance or other similar field.
  • Law Degree and admission to a state bar (with membership in good standing). Preferred Education :
  • 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.
  • Advanced tax research skills using online and print sources (Lexis, BNA, CCH, etc.).
  • Advanced writing skills including legal memo drafting and government submission drafting.
  • Experience with legal contract drafting, e.g. IP licenses, service agreements, etc.
  • 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.
  • Ability to manage multiple projects and priorities. Company Overview : English

Keywords: The Walt Disney Company (Corporate), Los Angeles , Manager, Tax Counsel Transfer Pricing, Accounting, Auditing , Glendale, California

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