Deloitte Tax Senior in New York, New York
Deloitte Tax LLP seeks a Tax Senior in New York, NY.
Work You ll Do
Help client management understand, plan for, and deal with the complex and dynamic issues surrounding global transfer pricing. Work with economists, attorneys, and tax specialists to analyze and resolve international tax and finance issues faced by multinational corporations. Provide assistance for multiple tax engagements, as well as offer expertise to help companies understand national, state and local, and international tax structures and align the tax function with business objectives. Research complex tax issues and ensure their resolution with the support of subordinate professional accountants. Provide analysis and business overview of client companies and industry trends in preparation of transfer pricing reports. Review and analyze financial statements and assist with overseeing the preparation and review of transfer pricing reports. Formulate tax planning strategies utilizing accounting methods and periods, capital transactions, corporate taxation, and IRS practice and procedures and assist in determining the potential impact of such development on client business. Responsible for incorporating financial information into a standard financial model and conducting economic, financial and accounting analysis. Draft engagement letters and other correspondence and administrative tasks related to business engagements. Utilize the latest technology and strategies to help clients work with complex and dynamic issues surrounding transfer pricing needs.
Bachelor's degree (or higher) in Economics, Finance, Accounting, or related field (willing to accept foreign education equivalent).
Eighteen months of experience preparing U.S. and foreign transfer pricing reports documenting intercompany transactions for various multinational companies.
Experience must include eighteen months of:
Reviewing technical aspects of the regulatory framework of transfer pricing documentation and consulting work within the following industries: electronics, automotive, industrial products, professional services, and healthcare;
Analyzing tangible goods, services, and intangibles under U.S. cost-sharing regulations and their OECD counterparts;
Working with remotely located personnel (domestically or internationally) and performing activities including assigning tasks, performing quality control, reviewing projects, and conducting comparable controlled transaction analyses;
Drafting transfer pricing reports for multi-lateral advance pricing agreements, business model optimization, and global tax compliance in accordance with IRC 482 and OECD guidelines;
Utilizing tax research tools, including BNA and LexisNexis, transfer pricing databases, including Compustat, Bureau van Dijk, Recap, RoyaltyStat, Osiris, S&P Capital IQ, Amadeus, and Thomson Reuter's ONESOURCE, and statistical software, including MS Excel and STATA programs designed to conduct transfer pricing analysis;
Applying new regulatory principles and guidelines under OECD'S Base Erosion and Profit Shifting (BEPS) initiative, preparing country-by-country reports, functional modules, Masterfile to document client's global business structure, and the functional and risk related information;
Performing quarterly ASC 740 reviews on transfer pricing reserves, and preparing and reviewing workpapers and memos;
Assisting with audit defense projects by responding to information document requests (IDRs) by the IRS on the client's business model and transfer pricing policies;
Utilizing various economic modeling methods, including discounted cash flow, realistic alternatives method, income method, residual profits method, services costs method, and other relevant methods as described in the U.S. Transfer pricing regulations under IRC 482 and their OECD counterparts, to perform valuation of intangible/tangible assets in the context of transfer pricing; and
Performing strategic transfer pricing planning, service cost allocation, audit defense, litigation support, and advance pricing agreement negotiations.
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