Transfer Pricing Manager

Allison Transmission•Indianapolis, IN

14h

About The Position

The Transfer Pricing Manager is a key role within Allison’s tax team that includes responsibilities that support preparation and review of U.S. international income tax calculations and modelling for tax accounting, tax return, and planning purposes. The position is multifaceted and includes monitoring and analysing U.S & foreign regulatory environment, audit controversy, and advising/supporting international restructuring projects. This position requires comprehensive understanding of U.S. international tax including GILTI (NCTI), BEAT, FDII, Subpart F and foreign tax credit to assist in preparation and review of income tax provisions and tax return filings. In addition, this role will oversee Allison’s global transfer pricing processes, including the preparation of financial analysis for intercompany billings, forecasting processes, tax return computations, and support audit defense of Allison’s transfer pricing regime. The position will collect and analyze financial data, prepare clear and well-organized supporting documentation, and work with both internal and external business partners to accomplish these goals.

Requirements

Bachelor’s Degree
Certified Public Accountant or CPA eligible
Minimum 7 years of overall corporate income tax experience and at least 5 years of US international tax experience
Extensive knowledge in US International tax laws
Transfer Pricing experience preferred
Strong analytical, critical thinking skills
Excellent time management, interpersonal, and communication skills
Understand complexity of US international tax regulations, intercompany sales/COS and managing impact on foreign operating margins related to Transfer Pricing
Understand complexity of new OECD Global Minimum Tax requirements and impact to overall company tax liability
Global tax oversight in over 25+ countries

Nice To Haves

Manufacturing & SAP/large ERP system experience a plus

Responsibilities

Responsible US International income tax compliance:
Lead contact with 3rd party external tax provider for ITAX related items: GILTI (NCTI), FDII, BEAT, Subpart F, and foreign tax credit
Communicate with foreign affiliates to capture compliance & provision info
Review foreign related party US GAAP prepared provisions
Support/communicate info needed for GloBE Return
Responsible for OECD/Pillar Two modelling & analysis
Monitor various countries OECD Global Min Tax positions
Support Federal/State quarterly tax estimate preparation w respect to ITAX
Responsible for Foreign Related Party OECD Transfer Pricing process:
Lead contact with 3rd party external tax provide to support in maintaining: Global Master Report (Mfg/Dist+) & various local files
Monthly monitoring of operating margins to forecast adjustments
Mid-year/year-end cost+ adder review and adjustments
Maintain cost+ Adder Summary & support regional communications
Research complex tax issues and knowledgably advise management of interpretation and application of tax laws and regulations
Support audit controversy, including correspondence IRS/State requests.
Demonstrate solid project management and excellent communication skills while interfacing with management, external advisors, and team members on complex technical topics, initiatives, and special projects.
Collaborate with internal and external business partners worldwide on international tax matters
Prepare/review various reports and analyses for internal use by management and external use by taxing authorities
Maintain various tax calendars
Identify/implement areas for tax process automation/improvement

Benefits

Choice of medical plans with prescription coverage
Employer HSA contribution
Dental & Vision Insurance
Paid Parental Leave
Short & Long-Term Disability
Other voluntary benefits including: Critical Illness, Hospital Indemnity, Identity Theft Protection and Pet Insurance
401K with generous Company match & contribution
Accrued Paid Time Off
12 Paid Holidays + 1 Floating Holiday
Robust employee wellness program
Tuition assistance program