Responsibilities:

• Collaborate with North American business group leaders and global transfer pricing team to co-develop transfer pricing strategies, objectives, and policies for the North America Region (aligned with global initiatives)
• Educate business group controllers about transfer pricing considerations and best practices
• Lead research and prepare expert opinions on a broad range of transfer pricing and international tax matters, including cross-border transactions
• Develop, implement and document BEPS-compliant transfer pricing systems to identify, ringfence, and proactively implement measures to mitigate transfer pricing risk
• Oversee the timely and accurate completion of transfer pricing documentation (i.e. local and master files) and adhere to regulatory requirements (i.e. statutory notifications and declarations) for US and Canadian operations
• Oversee outside transfer pricing service providers for Mexican and Costa Rican affiliates and support local tax team with transfer pricing matters
• Summarize status of local file documentation, quantify potential risks and recommend mitigating strategies
• Engage with outside service providers for transfer pricing technical support, benchmarking studies, and local file preparation assistance when necessary
• Team with business group controllers to drive proper accounting and periodic monitoring of operating margins and I/C pricing adjustments when necessary
• Collaborate with legal, tax, and global transfer pricing teams to proactively address transfer pricing audits and controversy
• Training and co-oversight of shared service center team assisting with preparation of routine local files
• Support US and Canadian tax compliance reporting related to transfer pricing, including but not limited to Form 5472, T-106, CbC and similar Pillar 2 intercompany transaction reporting requirements
• Participate in the preparation of intra-group contracts where transfer pricing arrangements are particularly relevant
• Support in matters relating to the assessment, declaration and taxation of permanent establishments
• Review double tax-treaties between the US and other jurisdictions and determine the applicability of such treaty on a transfer pricing matter / transaction
• Support the regional year-end tax provision process during the annual financial statement close

Qualifications:

• Bachelor’s degree in accounting and a master’s degree in accounting, finance, economics, or business required.
• 8+ years of combined transfer pricing and international tax experience from a national or regional public accounting firm, or fortune 500 company
• Executive presence - comfortable reporting to global and regional CFOs and business leaders, while still communicative and open-minded at all reporting levels
• Combination of large public accounting experience is a must; this coupled with large industry experience would profile the ideal candidate.
• Familiarity transfer pricing reporting tool or similar platforms preferred (currently using PWC's global Doc; previously Thompson Reuters transfer pricing platform)
• Transfer pricing regulatory experience using BNA/RIA/IBFD or similar databases.
• Experience with Hyperion Financial Management (HFM) is ideal.
• Excellent communication (both written and oral) and interpersonal skills
• Strong analytical and data interpretation skills
• Experience teaming with various business functional areas on project.
• Experience and proven practical knowledge of MS Office, specifically MS Excel.
• Experience working with manufacturing companies.
• Familiarity with US or Canadian corporate income tax a plus

Job Type: Full-time

Pay: $100,000.00 - $135,000.00 per year

Benefits:

• 401(k) matching
• Dental insurance
• Health insurance
• Life insurance
• Paid time off
• Vision insurance

Schedule:

• Monday to Friday

Application Question(s):

• Do you have 8+ years of combined transfer pricing and international tax experience from a national or regional public accounting firm, or fortune 500 company?

Experience:

• international tax: 8 years (Required)
• Pricing: 3 years (Preferred)

Ability to Relocate:

• Plymouth, MI 48170: Relocate before starting work (Required)

Work Location: Hybrid remote in Plymouth, MI 48170