Executive Director, Transfer Pricing and U.S. Tax Controversy

The Position
Leads global Transfer Pricing and U.S. Tax Controversy functions reporting to the Senior Vice President, Tax. Responsible for developing and managing global transfer pricing policies, pricing, documentation, and compliance; partnering with Tax and non-Tax business personnel on transfer pricing issues.
Also leads U.S. federal, state, and local Tax Controversy, developing strategy, handling cases, and coordinating communications with the IRS and state/local tax authorities.

Responsibilities
- Oversee Transfer Pricing planning globally and U.S. Tax Controversy matters.
- Direct transfer pricing across the supply chain; monitor intercompany transfer pricing to achieve year-end legal entity profitability targets.
- Analyze current and future transfer pricing strategies to mitigate risk and optimize efficiency.
- Develop and maintain global transfer pricing policies and U.S. documentation.
- Provide oversight/governance for transfer pricing documentation to meet U.S. and non-U.S. reporting requirements.
- Communicate transfer pricing policies and support implementation across business units and regions.
- Monitor compliance and advise on required adjustments; ensure compliance with U.S. and non-U.S. transfer pricing rules.
- Support Finance and Operations with transfer pricing implementation in systems and business processes.
- Manage relationships with outside service providers.
- Assist Tax Accounting on interim and annual tax provision and reporting.
- Conduct financial and economic analyses; advise on intercompany transactions.
- Oversee IP financial valuation models.
- Research and advise on changes in transfer pricing tax law and implications of proposed transactions.
- Partner with Controllers on Cost Sharing/R&D, IP management, logistics/procurement issues.
- Address service charges and management fees.
- Educate Finance and Operations on transfer pricing requirements and risks.
- Interview key employees and collaborate with HR on employee location/movement and evolving responsibilities.
- Lead a team of transfer pricing professionals for financial supply chain management, transfer pricing, and documentation.
- Monitor legislative changes and developments in U.S. and OECD transfer pricing regulations.
- Lead tax audits/examinations/appeals/litigation; coordinate IRS and other agency inquiries, prepare documentation, and negotiate settlements.
- Support audit defense and non-U.S. location needs with internal Tax and local Finance teams.

Required Education, Experience and Skills
- Bachelor’s degree in economics, finance, accounting, business, or related field.
- MBA, JD/LLM, and/or Master’s degree in relevant field (plus).
- 10+ years combined public accounting and/or corporate transfer pricing experience.
- Deep functional analysis and transfer pricing documentation experience.
- Experience implementing and maintaining tax-efficient supply chain structures.
- 5+ years planning projects involving IP transfers and principal models.
- Experience managing transfer pricing controversy.
- Experience partnering with IT, operations, and finance to build system solutions for transfer pricing requirements.
- Strong tax accounting knowledge and experience with multiple systems (e.g., Hyperion, SAP, Oracle).
- Strong understanding of corporate income tax matters and industry issues.
- Ability to identify, analyze, and communicate complex transfer pricing and tax issues and business impact.
- Experience identifying global and domestic transfer pricing issues/opportunities.
- Superior project management and leadership for large cross-functional teams.
- 5+ years managing and developing staff, including training.
- Strong written/verbal communication; ability to translate complex analyses for CFO and non-Tax employees.
- Strong organizational and leadership skills to manage Tax and cross-functional transfer pricing/controversy teams.