Senior Director, International Tax

Sr. Director, International Tax

The Coca-Cola Company and its affiliates do business in over 200 countries. The Senior Director, International Tax role is crucial to the Company. This position leads the Company's International Tax Planning and Compliance Group and is responsible for: Understanding and applying US international tax rules to our operations and transactions with minimal assistance from outside consultants; preparing documentation of tax technical positions taken by the Company and the outcome of those positions; communicating to the US audit firm tax technical positions of the company; understanding, quantifying, and documenting the impact of new legislation and regulations; reviewing US international tax-related income tax compliance; as well as responding and/or reviewing draft responses to IRS audit inquiries. This position requires a candidate who has deep tax technical knowledge (and has applied that knowledge in the multinational setting), strong writing skills with an ability to advocate, quantitative modeling skills, as well as someone that has demonstrated leadership skills and executive presence.

KEY RESPONSIBILITES

International Tax Law / Policy:

• Proactively monitor, analyze, understand, and communicate the tax cost or benefit associated with proposed or implemented changes to US and international rules and regulations.

• Working with General Tax Counsel, government policymakers, Company government relations teams, outside lobbyists, and coalitions on proposed legislation/regulations.
• Lead team tasked with implementing any such changes and ensuring reporting is correctly reflected.

• Identify international cross-border tax issues and the potential impact on the Company.
• Proactively design and evaluate tax planning and structuring ideas and determine the impact of such ideas from both a cash tax and ETR perspective.
• Lead the team tasked with implementing any such planning/structurings.
• Provide advice on the effects of ongoing and new business activities and the tax consequences, risks, and opportunities in the context of evolving and complex U.S. and foreign tax systems. Review documentation of any such items.
• Work with Tax Counsel, M&A, Treasury and Legal on potential M&A activity, including post-acquisition integration planning and execution.
  • Developing strategies for creating tax efficiencies in structuring such transactions.
  • Assist Tax Counsel with the tax, accounting, and treasury aspects of the implementation stage of the planning strategies, including assistance with creating legal entities and other work to ensure any related legal or operational requirements are followed.
  • Assist with review of tax provisions in contracts associated with M&A activity and Oversee preparation of documentation of any such transaction and liaise with EY partner overseeing US audit to ensure all open issues are resolved.
  • post-acquisition integration.

• Monitor the existence of, and any use of, tax attributes and design strategies to optimize their use.

• Reviewing and providing feedback on requests for authorization (RFAs) for capital projects/intercompany cash movements and other material transactions.
• Collaborating proactively with colleagues in the Tax Department, Treasury Department, Controller's Group, and operational finance to ensure that the tax implications of transactions are properly accounted for and described in quarterly financial statements, and tax filings. Be a principal point of contact for EY to discuss and align on the treatment of these transactions.

• Document positions taken on the tax return for use in answering future IDRs and discussions with the IRS. Consult with the Company's audit team to ensure that they understand how to explain the positions to the IRS.
• Collaborating with outside counsel/advisors on quantitative analysis for the US income tax impact to the Company of ongoing U.S. tax court and appellate litigation.
• Drafting responses and identifying appropriate documents and data in responding to requests from tax jurisdictions on audit in any country in which we operate.
• Supporting Tax Counsel in discussions with foreign tax officials on a variety of matters including being involved in such meetings.
• Collaborating with Tax Counsel and Transfer Pricing Team regarding efforts at negotiating Mutual Agreement Procedures and Advance Pricing Agreements.
• Collaborating with Tax Counsel on foreign tax audits and litigation.

• Oversee US international tax compliance team and review such compliance.
• Provide guidance to Accounting for Income Tax Team and the Controllers Group on appropriate reporting and accrual of income taxes.

• The ideal candidate is someone seen as a thought leader in the US international tax field, preferably someone with legislative experience and a minimum experience of ten years in international tax practice in the setting of a law firm, Big 4 Accounting Firm, similar-sized multinational corporation and/or government. Ideal candidate is a junior partner or director at a Big 4 or law firm.
• Advanced degree preferred such as J.D., LL.M., and/or Masters in Tax.