Tax Senior

Position Summary

Deloitte Tax LLP seeks a Tax Senior in San Jose, California.

Work You'll Do

Help client management understand, plan for, and deal with the complex and dynamic issues surrounding 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 provide multinational clients with professional economic analytical services. Research complex tax issues and ensure their resolution with the support of subordinate professional accountants. Provide analysis of client companies and industry trends in order to respond to client needs. Assist with overseeing the preparation and review of complex financial statements and transfer pricing reports. Formulate tax planning strategies utilizing accounting methods and periods, capital transactions, corporate taxation, and IRS practice and procedures. Assist with determining the potential impact of such developments on client business. Devise and execute database searches for companies in the U.S. and foreign markets. Responsible for incorporating financial information into a standard financial model and conducting economic, financial and accounting analysis. Draft proposals, reports, document requests and other correspondence related to business engagements. Review and analyze financial statements and transfer pricing reports, utilizing sophisticated software to devise and perform vital industry research and financial analyses.

• Bachelor's degree or higher in Economics, Finance, Accounting or related field (willing to accept foreign degree equivalent)
• 18 months of experience in preparing U.S. and foreign transfer pricing reports documenting intercompany transactions for various multinational companies
• Experience must include 18 months of:

• reviewing technical aspects of the regulatory framework of transfer pricing documentation, consulting work and analyzing U.S. regulations and their OECD counterparts;
• working with remotely located personnel, and performing activities including assigning tasks, performing quality control, reviewing projects, and conducting comparable controlled transaction analyses;
• drafting transfer pricing reports for global tax compliance and planning in accordance with IRC 482 and OECD guidelines;
• utilizing tax research tools, including, transfer pricing databases, including Compustat, Bureau van Dijk (Osiris and Amadeus), RoyaltyStat, S&P Capital IQ, and statistical software, and MS Excel and KROLL-cost of capital 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, preparing audits, and reviewing workpapers and memos;
• utilizing various economic modeling methods, including discounted cash flow, realistic alternatives, income, residual profits, services costs, 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.