Director (former job title Transfer Pricing Manager)

CLA (CliftonLarsonAllen)•Irvine, CA

25d•$245,066 - $272,850

About The Position

This role is for a Director, formerly known as a Transfer Pricing Manager. The position involves collaborating with small to mid-sized, privately held businesses both in the United States and internationally. The Director will lead a team dedicated to developing tax solutions that align with clients’ global business objectives and provide a comprehensive range of international tax services. Responsibilities include consulting on various issues, from helping clients expand globally for the first time to optimizing existing international structures and facilitating efficient cross-border transactions. The role requires designing and implementing transfer pricing policies and procedures that comply with OECD guidelines and local regulations, ensuring alignment with the client’s overall business objectives. The Director will apply various economic methods to determine arm's length prices, develop strategies for managing and resolving transfer pricing disputes, and oversee the preparation and maintenance of transfer pricing documentation. The position also involves conducting benchmarking studies, managing transfer pricing audits, and advising on planning, documentation, and controversy issues associated with inter-company transactions. Additionally, the role requires assisting companies with supply chain matters, translating information into quantitative and qualitative analyses, modeling financial outcomes, and managing multiple engagements. The Director will develop an understanding of clients’ needs to identify international tax planning opportunities, become a subject matter expert, and maintain technical expertise by staying current with industry and legislative changes. Business development, strengthening client relationships, and acting as a consultant on international business challenges are also key aspects of the role. The Director will research client international tax issues and apply solutions in areas such as foreign tax credit planning, mergers and acquisitions, repatriation of earnings, treaty analysis, and export sales incentives. The role includes preparing and reviewing the US international component of complex individual and corporate tax returns, and mentoring Associate and Senior International Tax team members.

Requirements

Bachelor's degree in Accounting, Finance, Economics or related field, plus 72 months of experience evidencing demonstrable ability to perform the stated job duties.
Alternatively, a Master's degree in Accounting, Finance, Economics, or related field, or a Juris Doctor (J.D.) degree, plus 48 months of experience evidencing demonstrable ability to perform the stated job duties.
Must be a Certified Public Accountant or hold a Juris Doctor or other advanced degree in a related field.
Knowledge of and experience with transfer pricing, international tax compliance and consulting, international tax concepts and Organisation for Economic Co-operation and Development (OECD) guidelines, tax provisions and FIN 48/ASC 750 and Uncertain Tax Positions (UTPs), advance pricing agreements (APAs), mutual agreement procedures (MAPs), analytical and economic modeling, research on client international tax issues, client relationship management, staff mentoring.
Proficiency in TP Catalyst, Royalty Range, Caseware, GOSystems, tax research databases, and Microsoft Suite products.

Responsibilities

Lead a team dedicated to developing tax solutions that align with clients’ global business objectives and provide a comprehensive range of international tax services.
Consult on various issues, from helping clients expand globally for the first time to optimizing existing international structures and facilitating efficient cross-border transactions.
Design and implement transfer pricing policies and procedures that comply with OECD guidelines and local regulations.
Ensure alignment of transfer pricing strategies with the client’s overall business objectives.
Apply various economic methods, such as the Comparable Uncontrolled Price (CUP) method, Resale Price Method, Cost Plus Method, and Transactional Net Margin Method (TNMM), to determine arm's length prices.
Develop strategies for managing and resolving transfer pricing disputes, including advance pricing agreements (APAs) and mutual agreement procedures (MAPs).
Oversee the preparation and maintenance of transfer pricing documentation, including master files, local files, and country-by-country reports.
Conduct benchmarking studies and economic analyses to support transfer pricing positions.
Manage transfer pricing audits and inquiries from tax authorities.
Review and advise on planning, documentation, and controversy issues associated with all types of inter-company transactions.
Assist companies with supply chain matters and help them accurately reflect and monitor their transfer pricing in financial systems.
Translate information from various sources into quantitative and qualitative analyses to inform and advise clients.
Provide a fully integrated approach to transfer pricing by preparing documents and assisting in defending transfer pricing in audits.
Model financial outcomes, value intangible assets, and develop practical planning approaches.
Manage and schedule multiple engagements.
Develop an understanding of clients’ needs to identify international tax planning opportunities.
Become a subject matter expert for the engagement team.
Maintain technical expertise by staying current with industry and legislative changes.
Participate in local office and firm-wide business development opportunities.
Strengthen existing client relationships and introduce clients to other services.
Act as a consultant on a wide range of international business challenges, from going international for the first time to optimizing existing structures and implementing efficient cross-border transactions.
Efficiently research client international tax issues and apply solutions in areas such as foreign tax credit planning, mergers and acquisitions, repatriation of earnings, treaty analysis, and export sales incentives.
Prepare and review the US international component of complex individual and corporate tax returns.
Act as a mentor and point of escalation for Associate and Senior International Tax team members.