Tax Professional u2013 Global Transfer Pricing
Posted on: 6 Apr 2021
Armonk, NY
Job Description
Introduction
At IBM, work is more than a job its a calling: To build. To design. To code. To consult. To think along with clients and sell. To make markets. To invent. To collaborate. Not just to do something better, but to attempt things youve never thought possible. Are you ready to lead in this new era of technology and solve some of the worlds most challenging problems? If so, lets talk.
Your Role and Responsibilities
IBM is seeking candidates to join its global transfer pricing and valuation practice. Transfer Pricing is a multi-disciplinary specialty engaged in evaluating cross-border intercompany payments and flows, engaging various stakeholders (including tax authorities, IBM finance, IBM intellectual property lawyers, and others within the broader organization), valuation, supply chain analysis and global documentation.
This is a challenging and fast paced position that requires a candidate to understand IBMs complex business structure, liaison with internal and external stakeholders, understand the history of legal agreements and have a working understanding of financial reports used in cross-border inter-company transactions involving flows of goods, services and intangible property.
Job Duties:
* Take a leadership role in drafting intercompany legal agreements, memorandums, and engage with international tax to understand intercompany flows associated with a given transaction;
* Assist in preparing audit analyses, support audit-ready files and draft memoranda/reports, as appropriate;
* Take a leadership role for inter-company matters with legal, accounting, financial planning and external reporting foreign controllers, business managers and tax departments;
* Be responsible for drafting Transfer Pricing Documentation (including 482 and MasterFile) for all businesses within IBM, review of local files as appropriate;
* Interact with tax and business executives, present transfer pricing planning strategies, answer technical questions, intercompany legal agreement/structuring questions, or other business information required for transfer pricing studies; and
* Have a working knowledge for developing financial models to evaluate audit risks and opportunities for transfer pricing projects.
Required Technical and Professional Expertise
* JD, LLM or a Masters Degree in Taxation and/or CPA (or equivalent)
* At least 6 years of experience in Transfer Pricing
* Demonstrate ability to work both autonomously and in a team environment
* Strong writing skills and focus on details
* Strong analytical skills and experience with MS Word, PPT, and Excel
* Excellent time management, communication (verbal and written), decision-making, presentation, interpersonal and organizational skills
Preferred Technical and Professional Expertise
* None
* None
IBM
Armonk, New York
International Business Machines Corporation operates as an integrated technology and services company worldwide. Its Cognitive Solutions segment offers a portfolio of enterprise artificial intelligence platforms, such as analytics and data management platforms, cloud data services, talent management, and industry solutions primarily under the Watson Platform, Watson Health, and Watson Internet of Things names. This segment also offers transaction processing software for use in banking, airlines, and retail industries.
The company’s Global Business Services segment offers business consulting services; delivers system integration, application management, maintenance, and support services for packaged software applications; and finance, procurement, talent and engagement, and industry-specific business process outsourcing services. Its Technology Services & Cloud Platforms segment provides project, managed, outsourcing, and cloud-delivered services for enterprise IT infrastructure environments; technical support, and software and solution support services; and integration software solutions. The company’s Systems segment offers servers for businesses, cloud service providers, and scientific computing organizations; data storage products and solutions; and z/OS, an enterprise operating system.
Its Global Financing segment provides lease, installment payment plans, and loan financing services; short-term working capital financing to suppliers, distributors, and resellers; and remanufacturing and remarketing services. International Business Machines Corporation serves financial services institutions, airlines, manufacturers, and consumer goods and retail companies. The company was formerly known as Computing-Tabulating-Recording Co. and changed its name to International Business Machines Corporation in 1924. The company was incorporated in 1911 and is headquartered in Armonk, New York.
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IndustryInformation Technology
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No. of Employees350,600
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Website
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Jobs Posted4684
