Assistant Tax Counsel

Job Description

Job Description

• Evaluate the technical merits of internally and externally developed tax strategies, identifying issues and opportunities, and present conclusions, opinions and recommendations. Research and draft memoranda documenting positions taken.
• Work closely with the transfer pricing team to address global transfer pricing policy issues and audits.
• Partner with the US and international tax team to drive effective US and foreign country tax planning.
• Stay abreast of changes in U.S. federal tax law as well as the tax law in key foreign jurisdictions and develop strategies to capitalize on opportunities, avoid pitfalls, and ensure adequate and efficient compliance.
• Review ongoing and new business activities including legal entity structuring projects and provide advice on the tax consequences, risks and opportunities.
• Provide tax planning advice and assist with tax modeling for M&A and other material Company transactions, including integration planning and execution.
• Advise senior corporate and operations executives regarding tax efficient methods of accomplishing acquisitions and dispositions, assist in the drafting of related agreements, and performing associated tax due diligence. Engage with outside advisors and third-party sellers/buyers in negotiating the tax aspects of M&A transactions.
• Work closely with domestic and foreign treasury personnel to manage tax issues associated with third-party financing arrangements and intercompany finance structures and funding requirements, including leverage planning and repatriation strategies and planning.
• Manage and assist with federal, state and local, and foreign tax controversies (audits and litigation).
• Evaluate the financial accounting implications of uncertain tax positions and recommend appropriate FIN 48 reserves.
• Ensure that tax planning initiatives, M&A and other material transactions are properly reflected and recorded for tax accounting, financial reporting purposes and in the Company's tax provision and relevant tax returns.
• Manage relationships with outside advisors regarding planning, return preparation, and audits.
• Experience in leading and advising on global mergers and acquisitions and business structures and transactions.
• Develop continuous improvement practices including the use of technology for the tax function to become more efficient and accurate in compliance work and to utilize best practices that are feasible and appropriate.