Director of International Tax (San Jose, CA)
Our client is a high technology company headquartered in San Jose, CA who is searching for a Director of International Tax. As a member of a global tax team, you will direct international and foreign tax planning, management of international tax controversies, providing tax leadership in acquisitions, reorganizations, and divestitures with international elements. You will also manage a team that handles international portions of the tax provisions and international compliance. You will evaluate global tax situation and provide advice on international tax planning strategies to optimize results. Within Transfer Pricing Management, you will implement global transfer pricing policies and monitor compliance with them, establish and maintain transfer pricing documentation requirements in multiple jurisdictions, analyze individual company operating results periodically and make, as appropriate, adjustments to inter-company pricing and coordinate with local financial departments on the calculation, accounting treatment, and documentation of any correlative adjustments. You will draft and review inter-company contracts consistent with the company’s transfer pricing policies and inter-company transactional relationships, identify local transfer pricing requirements and develop strategies for preparing documentation studies and other support as necessary for penalty avoidance and manage transfer price and other international queries under audit. Within Foreign Tax Credit Planning, you will be responsible for analyzing US tax deferral opportunities, minimizing transactional taxes such as withholding taxes, consumption taxes, VAT and others, and for blending foreign tax credit pools for maximum benefit of dividend remittances. The Director of International Tax will oversee and maintain E&P pools for our foreign subsidiaries and international tax compliance including preparation of Forms 5471 and other international forms (e.g.: 926, 1118, 1120-F, 5713, 8821, 8832, 8858, and 8865). Within Sarbanes-Oxley Compliance (404), the Director of International Tax is responsible for evaluating control procedures necessary to assure compliance with foreign tax requirements by foreign subsidiaries as well as accurate reporting of tax transactions to headquarters. You will also be responsible for establishing and monitoring compliance with these control procedures, this includes evaluating financial and tax systems for 404 purposes. Additional duties of the Director of International Tax will include overseeing FAS 109 calculations for international transactions and for foreign subsidiaries and affiliates by analyzing local tax positions taken (UTB’s and any associated penalties and interest) for FIN 48 purposes; You will also be responsible for managing and training the international tax staff on all aspects of tax compliance, research, planning, audit documentation and issue resolution. This role requires Bachelors in Accounting, a Masters in Taxation and/or a law degree including State Bar membership, an LLM and/or a CPA is preferred.