Primary duties & responsibilities:
Reporting to the International Senior Tax Manager, this position will support all aspects of US outbound international and transfer pricing matters of a US-based technology multinational Corporation.
- Assist with various US International tax calculations and analyses including E&P, FTC positions, Subpart-F, GILTI, FDII, and BEAT for planning, quarterly & year end provision and compliance purposes
- Managing international components of the co-sourced US tax compliance process, including all related computations, forms, disclosures & schedules.
- Assist with modelling and analyzing scenarios to assess and advise on potential tax implications from operational changes, restructuring initiatives, and tax law changes.
- Project management on critical tax restructuring projects such as IP onshoring and buy-sell conversion.
- Review contracts and collaborate with legal and the business to ensure contracts contain key terms consistent with global tax structure
- Assist in international tax planning, including subpart F minimization, repatriation, intercompany funding, foreign tax credit and foreign source income planning, international M&A, Federal legislative planning, and non-US ETR planning. Identifying and developing opportunities for ETR, cash, go-to-market and supply-chain efficiencies
- Partnering with regional finance and tax personnel to review and provide feedback as needed on foreign reporting packages and tax provisions at quarter-end and year-end, as well as provision-to-return true-up analysis.
- Manage post-acquisition restructuring of target’s IP and legal entity footprint
- Monitoring and assessing proposed tax legislation in the U.S. and significant foreign jurisdictions and assess impact to Company and for potential opportunities, exposures, and mitigating strategies.
- Review Permanent Establishment risk identifiers and metrics and implementation of strategies to mitigate PE risk.
- Supporting transfer pricing planning, maintenance, calculations, documentation and potential for automation for intercompany transactions such as royalty, cost sharing, management fee, and profitability of foreign cost+ and limited risk distributor subsidiaries. This is a co-sourced relationship with outside service providers.
- Supporting & defending US international audit issues and foreign tax audits.
- Research and advise business divisions and local finance team on global withholding tax requirements.
- Supporting tax technology, automation, and process improvement initiatives as it relates to international tax matters and computations.
- BA/BS in accounting; Masters in Taxation and/or CPA and/or JD preferred
- Minimum 6+ years overall experience with US multinational tax operations
- Preference for combination of public company industry and Big 4 background
- Strong technical experience in US international tax. US GAAP income tax accounting experience with international tax matters preferred.
- Results-driven with a high level of initiative, urgency, accountability and integrity
- Strong excel skills or an enthusiasm to strengthen such skills for efficiencies
- Strong project management and organizational skills to managing projects involving external advisors, auditors, regional finance, and business teams. Partnering and developing relationships with various groups to ensure cross-functional alignment throughout the organization.
- Strong verbal and written communication skills and capable of explaining work products and calculations to non-tax cross functional teams and business leaders.
- Proven track record to meet various deadlines associated with day-to-day responsibilities alongside special project-work
Arista is an Equal Opportunity Employer: All qualified applicants will receive consideration for employment without regard to race, sex, color, religion, national origin, protected veteran status, or on the basis of disability.