Senior Director, International Tax

Coca-Cola•Atlanta, GA

11h•Hybrid

About The Position

The Senior Director, International Tax role is crucial to The Coca-Cola Company, which operates in over 200 countries. This position leads the Company’s International Tax Planning and Compliance Group. The role involves understanding and applying US international tax rules to operations and transactions with minimal outside consultant assistance, preparing documentation for tax technical positions and their outcomes, communicating these positions to the US audit firm, understanding, quantifying, and documenting the impact of new legislation and regulations, reviewing US international tax-related income tax compliance, and responding to or reviewing responses for IRS audit inquiries. The position requires deep tax technical knowledge applied in a multinational setting, strong writing and advocacy skills, quantitative modeling abilities, demonstrated leadership, and executive presence.

Requirements

Minimum 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.
Deep tax technical knowledge applied in a multinational setting.
Strong writing skills with an ability to advocate.
Quantitative modeling skills.
Demonstrated leadership skills and executive presence.
Currently authorized to work in the United States on a full-time basis and must not require The Coca-Cola Company's sponsorship to continue to work legally in the United States.

Nice To Haves

Legislative experience.
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.

Responsibilities

Proactively monitor, analyze, understand, and communicate the tax cost or benefit associated with proposed or implemented changes to US and international rules and regulations.
Work 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 their potential impact on the Company.
Proactively design and evaluate tax planning and structuring ideas and determine their impact 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.
Develop strategies for creating tax efficiencies in structuring such transactions.
Assist Tax Counsel with the tax, accounting, and treasury aspects of the implementation stage of 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.
Oversee preparation of documentation of any such transaction and liaise with EY partner overseeing US audit to ensure all open issues are resolved.
Monitor the existence of, and any use of, tax attributes and design strategies to optimize their use.
Review and provide feedback on requests for authorization (RFAs) for capital projects/intercompany cash movements and other material transactions.
Collaborate 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.
Act as 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.
Collaborate 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.
Draft responses and identify appropriate documents and data in responding to requests from tax jurisdictions on audit in any country in which we operate.
Support Tax Counsel in discussions with foreign tax officials on a variety of matters including being involved in such meetings.
Collaborate with Tax Counsel and Transfer Pricing Team regarding efforts at negotiating Mutual Agreement Procedures and Advance Pricing Agreements.
Collaborate 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.