Senior Director, Global Tax Planning & Controversy

Block•Bay Area, CA, United States of America, CA

2d•$251,600 - $377,400•Remote

About The Position

Block is looking for a Senior Director, Global Tax Planning and Controversy. Reporting to the Chief Accounting Officer, you will lead Block's global tax planning, international tax, transfer pricing strategy, M&A and investment tax activities, U.S. federal and state income tax planning, and direct tax controversy agenda and significant tax examinations and disputes. You will help shape Block's global legal-entity, financing, IP, and operating structures, and translate complex tax concepts into practical business solutions. This is a highly visible, hands-on role requiring exceptional technical judgment, commercial awareness, and executive presence.

Requirements

15+ years of multinational corporate income tax experience spanning complex global tax planning, M&A, and tax controversy.
In-house tax experience at a publicly traded multinational, advising senior executives and cross-functional partners on material tax matters.
Deep U.S. international tax expertise: cross-boarder tax, foreign tax credits, treaties, withholding, permanent establishment, cross-boarder financing, and transfer pricing.
Deep U.S. federal corporate tax knowledge: Subchapter C, consolidated returns, reorganizations, financing transactions, and attribute limitation rules.
A track record of developing and executing sophisticated tax-planning strategies and leading domestic and cross-border transactions end-to-end, including negotiating tax terms and developing negotiation positions.
Success managing significant U.S. and foreign income tax audits, developing defensible technical positions, and resolving disputes with tax authorities.
Strong research, modeling, and technical-writing skills, with sound judgment in areas of uncertainty.
Executive presence and a proven record of building high-performing teams.

Nice To Haves

Big Four accounting firm experience in addition to substantial in-house public-company experience.
MS in Taxation, JD/LLM in Taxation, CPA, or comparable credentials.
Background in technology, payments, fintech, digital assets, or another highly regulated industry.
Experience with Treasury initiatives such as capital markets, global cash pooling, intercompany lending, debt restructurings, and capital allocation.
Experience partnering with government relations or tax-policy teams.
Experience applying tax technology, analytics, and AI to analysis, modeling, and audit readiness.

Responsibilities

Develop and execute Block's global tax planning strategies in alignment with business objectives, financial priorities, and risk tolerance. Identify opportunities, evaluate alternatives, and lead the implementation of sustainable, defensible domestic and international tax planning.
Lead international tax planning related to Block's global operations, including cross-border legal-entity structures, intellectual-property arrangements, intercompany transactions, financing, capital deployment, cash repatriation, and operating-model changes. Advise on complex U.S. international and foreign tax matters such as foreign tax credits, tax treaties, withholding taxes, permanent-establishment considerations, transfer pricing, and global minimum tax regimes.
Own U.S. federal and state income tax planning, including consolidated return matters, financing transactions, the preservation and use of tax attributes, nexus and apportionment planning, sourcing positions, filing methodology and entity structure.
Analyze tax considerations for new product launches, product modifications, and new market entry or expansion efforts. Act as a thought partner to the business by collaboratively developing alternative solutions to support business initiatives.
Monitor U.S. and international legislative, regulatory, administrative, judicial, and policy developments. Assess their potential impact on Block's global structure, cash taxes, effective tax rate, financial reporting, and compliance obligations, and develop strategies to address material risks and opportunities.
Lead the tax aspects of domestic and cross-border acquisitions, dispositions, investments, joint ventures, strategic partnerships, reorganizations, and other corporate transactions — from initial evaluation through due diligence, structuring, modeling, negotiation, closing, integration, and tax return implementation. Develop and evaluate alternative transaction structures, advising senior leadership on cash-tax consequences, effective-tax-rate implications, use of tax attributes, and potential controversy risks.
Partner with Corporate Development and Legal in negotiating transactions. Review, draft, and negotiate tax provisions in purchase agreements, investment agreements, commercial contracts, and other transaction documents, including tax representations, covenants, indemnities, purchase-price provisions, and withholding obligations and the allocation of pre- and post-closing taxes.
Own Block's direct tax controversy strategy across federal, state, local, and foreign income tax examinations — from audit readiness and risk assessment through information-document requests, administrative appeals, competent-authority proceedings, settlement negotiations, and final resolution. Develop strategies for international tax controversies, including transfer-pricing disputes, permanent-establishment matters, withholding-tax and treaty-based disputes.
Serve as a senior representative of Block in interactions with U.S. and foreign tax authorities. Develop audit-defense and dispute-resolution strategies supported by strong technical analysis, contemporaneous documentation, and quantitative modeling.
Partner cross-functionally with Tax Reporting & Compliance, Legal, Corporate Development, Treasury, Accounting, FP&A, Product, People, Government Relations, and business leadership. Ensure domestic and international tax considerations are incorporated early in strategic and operational decision-making. Ensure that planning, transaction structures, uncertain tax positions, and audit resolutions are properly reflected in the tax provision, financial statement disclosures, and filed tax returns through close partnership and collaboration with Tax Reporting & Compliance.