Transfer Pricing-Valuation Senior Associate/Manager
IBM Tax is seeking a Transfer Pricing Manager with some focus on valuation projects to work in the Transfer Pricing Group at IBM headquarters located in Armonk, NY. This group engages in transfer pricing planning, valuation, global documentation, and controversy. In addition, the TP Group supports IBM's hardware, software and services businesses, as well as the international tax planning, state and local, operations and controversy tax groups.
The position would report to the global leader of TP Planning and Operations and will be responsible primarily for delivering economic analyses related to valuation of intellectual property and legal entities in the context of acquisitions, financial modeling to evaluate transfer pricing planning opportunities in areas such as cost sharing, intellectual property migration, intercompany licensing and hardware pricing. The candidate may coordinate other type of projects as needed such as TP documentation or controversy support.
Specific primary responsibilities include:
- Valuation of acquired entities or assets for transfer pricing, and to a lesser extent book purposes. Analysis of PPA's and reconciliation with TP valuations.
- Autonomously lead transfer pricing planning projects to successful completion (including fact finding, analyzing data, drafting memorandums and presentation to management).
- Interact with tax and business executives, present transfer pricing planning strategies, answer technical questions and gather data or other business information required for transfer pricing studies
- Provide economic support to global transfer pricing audit teams in connection with transfer pricing inquiries from tax authorities.
Required Technical and Professional Expertise
- At least 5 years of experience in transfer pricing either in-house or at accounting firms with solid exposure to transfer pricing valuation-type projects. Alternatively, candidates with at least 5 years of non-TP corporate valuation experience and desire to practice transfer pricing will be considered.
- English: Fluent and able to produce professionally written documents
Preferred Tech and Prof Experience
- Masters in finance, CFA or equivalent preferred but not a requisite.
IBM is committed to creating a diverse environment and is proud to be an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, gender, gender identity or expression, sexual orientation, national origin, genetics, disability, age, or veteran status. IBM is also committed to compliance with all fair employment practices regarding citizenship and immigration status.
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