3 days old

Tax Director of Controversy and Transfer Pricing

Samsung
Ridgefield Park, NJ 07660

Position Summary

Making the future is everyday life at Samsung. Were seeking innovators who are called to not just change the world, but build a better one. We enable the best technology hardware on the planet, but our best is always a prototype for something better and our people thrive with a driven mindset better builds on better. We believe that innovation and growth are driven by an inclusive culture and a diverse workforce. We aim to create a global team where everyone belongs and has equal opportunities, inspiring our talent to be their true selves. Together, we are building a better tomorrow for our customers, partners and communities.

The Tax Director of Controversy, Transfer Pricing and Special Projects will be responsible for coordinating and supporting these respective functions on behalf of the Samsung Electronics America, Inc. and Subsidiaries North American Group (SEA) and will directly report to the North American Headquarters Head of Tax with focused efforts to achieve our Corporate Tax Strategy to take a sustainable approach to taxes which is commercially driven, responsible and transparent. Responsibilities also include various facets to support tax operations matters involving internal non-income tax compliance reporting, proactive business consultation and planning, tax strategy implementation, tax risk assessment and mitigation, optimizing tax incentives, and providing leadership to Tax Department senior management in order to accomplish these imperatives.

Also, this role will provide assistance and support with the development and supervision of assigned Tax Department tax managers and staff to ensure adherence to departmental timelines, maintain compliance procedures and controls. Continual interaction and collaboration with SEA finance, legal, HR, distribution, and other shared departments, Samsung affiliates, external financial auditors, tax providers and with Samsungs South Korea Corporate Headquarters Tax Department. Experienced tax department professionals and outside advisors will support and report into this position. With inspiration from our Samsung corporate strategies and interactive organizational training, this role will foster Tax Director leadership to support ensuring best in class outcomes through continuous engagement with key stakeholders and developing self, team and organization.

Role and Responsibilities

Tax Controversy

  • Develop and execute tax controversy strategies to effectively defend tax positions taken and minimize controversy related adjustments including negotiations to arrive at an acceptable settlement
  • Develop and execute tax audit strategies; effectively manage all US income federal, state, and local audits
  • Comprehend statutory authority and develop audit strategies to contend company tax positions
  • Develop effective working relationships with tax authorities
  • Manage tax risk issues
  • Provide guidance on tax risk profile, materiality, and risk-based approach across the department
  • Manage IDR process and develop optimal response strategy
  • Partner with a wide range of stakeholders within and outside the tax function to support tax positions subject to audit, including Legal, Accounting and Finance
  • Perform research and analysis to understand facts and tax technical implications of controversy issues
  • Engage and partner with external providers as appropriate to ensure proper representation and advice on matters under inquiry
  • Investigate and resolve periodic tax notice inquiries from the IRS, state and local taxing authorities
  • Represents the Company before various taxing authorities; coordinates with IRS, federal and various other state agencies for tax matter resolution

Transfer Pricing

  • Manage and coordinate Advanced Pricing Agreements (APA) including the reporting and filing of the related APA annual reports and oversight of competent authority matters with respective US and non-US taxing authorities with the support of SEAs external tax providers
  • Ensure and document transfer pricing tested transactions on a quarterly and annual basis
  • Drive global transfer pricing policies and review reports and analysis provided by third party providers
  • Provide the Tax Compliance/Reporting Group with understanding a working knowledge of the group transfer pricing methodology to ensure appropriate financial reporting and tax return filing positions

Financial Tax Reporting

  • Proactively communicate and work with broader Corporate tax team to assess exposure in current and future positions
  • Assess uncertain tax position and determine reserve requirements; draft memorandum substantiating any related financial statement impact in accordance with IAS 12

Tax Planning

  • Provides tax support for M&A activities, including managing tax due diligence and tax planning
  • Monitor, analyze, and advocate on tax legislative and regulatory developments
  • Assist with the analysis of M&A transactions for areas of tax risk and opportunities
  • Works with outside tax advisors on key strategic projects and tax planning initiatives, as required

Research and Development Credits

  • Oversee and manage the federal and state research and development income tax credits for the SEA North American Group
  • Coordinate with outside tax advisors to compile the supporting documentation and compilation of the required contemporaneous documentation required by the IRS and state taxing authorities
  • Support the review of quarterly and annual estimated and forecasted credits for financial tax reporting purposes
  • Responsible for supporting SEA claimed credits with both the federal and state taxing jurisdictions

Skills and Qualifications

Additional Responsibilities

  • Oversee and assure compliance with all outside of the U.S. tax return obligations and tax payments, ensuring all international entity tax compliance (US tax withholding and FBAR) is completed and filed timely
  • Experience with federal 1099 Reporting requirements a plus
  • Provides leadership and strategic guidance to the Tax Compliance Department personnel
  • Interacts and advises North American business units by serving as a subject matter expert on tax related matters
  • May support the Tax Compliance Department with review of US tax filings (income and gross receipts taxes)
  • Supports and provides an analysis of complex issues, including written memoranda of potential tax accounting issues and related transactions that may significantly impact the SEA Group as needed
  • Connects with colleagues across the business to resolve issues, develop strategies and improve processes
  • Support with the design and implementation of improvements in tax processes that are aligned with corporate compliance, financial reporting and planning initiatives
  • Performs and directs tax research as required
  • Develops and maintains in-depth knowledge of federal, state, and foreign tax developments that may be relevant to the Company
  • Performs supervisory responsibilities in accordance with the organizations policies and applicable law
  • Support the Head of Tax with Samsungs Government Affairs Group. Maintain relationships with key Tax industry organizations such as Global Business Alliance, Tax Executive Institute and Committee on State Taxation. Secure knowledge sharing, best practices and build external network
  • Work with key internal business partners and external stakeholders to develop and advocate on U.S. State tax policy supporting SEAs priorities
  • Understand SEAs research development, manufacturing and commercial operations to be in optimal position to provide tax advice to stakeholders
  • Consistently engage with SEA affiliates to ensure proper tax reporting, identify and enable tax planning opportunities and identify and manage related risk. As part, build and maintain relationships with key stakeholders
  • Support business in assessment of permanent establishment tax risk in collaboration with Corporate Tax with tax advice to limit exposure
  • Ensure elections, attachments, disclosures and statements are completed accurately. Determine proper tax treatment of tax positions and transactions pertaining to taxable income reported on the Federal and State tax returns
  • Ensures that organization complies with periodic tax payments, information reporting and other taxing authority requirements
  • Organizes and maintains tax records as required by tax authorities. Ability to effectively compose comprehensive tax memoranda including authoritative citations of relevant tax provisions and/or case law in order to document company tax positions
  • Keep abreast of technical issues related to Federal, state and local tax developments/strategies.
  • Ensures compliance with all Company policies and procedures, including safety rules and regulations
  • Performs related duties as assigned; meets internal deadlines for timely delivery of assigned tasks
  • Establish and maintain internal relationships with affiliated company personal and external tax/auditor professionals. Liaise with other Tax, Finance, and Accounting department personnel
  • Contribute to the overall success of the team by keeping Senior Tax Leadership informed of work status; proactively evaluating tax saving and effective tax rate reduction opportunities; challenging traditional procedures used in the past; and attempting to find new approaches
  • Implement managerial responsibilities in accordance with the companys policies, procedures, federal, state and local laws

Software

  • Experience with Microsoft Office Tools (Excel, PowerPoint, Word, and Outlook) and Adobe Acrobat
  • Experience with OneSource Income Tax and supporting schedules a plus
  • Experience with tax research databases such as Checkpoint, CCH and BNA

Required Knowledge and Skills:

Knowledge of:

  • Generally Accepted Accounting and Auditing Principles, practices and methods.
  • Business and personal computer hardware and software applications.
  • Business English usage, spelling, grammar and punctuation.
  • Pertinent federal, state and local tax laws, codes and regulations.
  • Financial audits, practices and applications.
  • Supervision and training practices and methods.
  • Principles of mathematical and statistical computations.
  • Current Company policies, practices and procedures, including safety rules and regulations.

Skill in:

  • Ability to think strategically and creatively about business goals and global tax planning initiatives and impacts.
  • Knowledge of transfer pricing frameworks and methodologies
  • Experience with corporate taxation and consolidations.
  • Prior experience preparing tax provisions.
  • Developing and implementing goals, objectives and practices for effective, efficient and cost effective management of allocated resources.
  • Responding to inquiries or complaints from federal and state regulatory agencies.
  • Communicating clearly and concisely, both orally and in writing.
  • Reading, analyzing, interpreting and applying financial and tax manuals, accounting journals, financial reports, legal documents, and federal, state and local tax related laws, codes and regulations.
  • Researching, analyzing and evaluating new tax saving methods, procedures and programs.
  • Supervising, coordinating, delegating assignments and reviewing the work of assigned department personnel.
  • Establishing and maintaining cooperative working relationships with others.
  • Ability to effectively delegate work as needed.
  • Train other team members.
  • Strong analytical, research and critical thinking skills.
  • Able to work well in a team environment.
  • Demonstrate an understanding of increasingly complex tax concepts. Discuss moderately complex tax issues with the team. Keep informed of current tax developments and effectively apply tax knowledge to client situations.
  • Building on technical competence by keeping up to date on trends, developments and technical authorities and apply them to complex situations.
  • Demonstrating professionalism through a positive and cooperative attitude and by maintaining the confidential and proprietary nature of work products.

Physical Requirements and Working Conditions: Incumbents in this class are subject to extended periods of sitting, standing and walking, vision to monitor, moderate noise levels and periodic business travel. Work is performed in an office environment.

Minimum Qualifications: Bachelor's Degree in Accounting or Finance with CPA license, Masters in Tax or JD with LLM in Taxation preferred. Minimum twelve years of progressive experience in public accounting and/or multinational corporate tax department. Strong technical knowledge with experience covering a broad range of complex U.S. Federal, State and International tax matters. Must have in-depth knowledge of IFRS tax accounting rules and pronouncements. Must have intermediate/advanced knowledge of Microsoft Office, specifically Excel. Requires strong business acumen and analytical skills, excellent verbal and written communication skills and a proven record of the highest level of personal integrity. Requires a least 10 years of supervisory experience with demonstrated ability to generate team engagement, collaboration, development, credibility and commitment. Extensive experience with transfer pricing methodologies and cross border transactions, tax compliance, tax accounting, financial reporting, tax audits and controversy, tax advisement and internal and external stakeholder management. Must be a team player and possess a strong dedication to providing quality service. Must be attentive to detail, accuracy, and the ability to use judgment to make sound decisions. Must have strong organizational skills and the ability to take ownership and work autonomously. Ability to be flexibility and work to meet regulatory and internal deadlines is imperative.

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* Samsung Electronics America, Inc. and its subsidiaries are committed to employing a diverse workforce, and provide Equal Employment Opportunity for all individuals regardless of race, color, religion, gender, age, national origin, marital status, sexual orientation, gender identity, status as a protected veteran, genetic information, status as a qualified individual with a disability, or any other characteristic protected by law.

COVID-19 Vaccine Mandate

In order to comply with the federal vaccine mandate, Samsung Electronics America requires all employees to be fully vaccinated against COVID-19, unless a medical or religious exemption, or an exemption required under state/local law, is approved. Offers of employment are contingent upon proof that a candidate is fully vaccinated or qualifies for an exemption. More details on how to apply for an exemption are provided after the application process is complete.

Reasonable Accommodations for Qualified Individuals with Disabilities During the Application Process

Samsung Electronics America is committed to providing reasonable accommodations for qualified individuals with disabilities in our job application process.If you have a disability and require a reasonable accommodation in order to participate in the application process, please contact our Reasonable Accommodation Team (855-557-3247) or SEA_Accommodations_Ext@sea.samsung.com for assistance. This number is for accommodation requests only and is not intended for general employment inquiries.


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Samsung Electronics is a global leader in technology, opening new possibilities for people everywhere. Through relentless innovation and discovery, we are transforming the worlds of TVs, smartphones, wearable devices, tablets, digital appliances, and network systems, and the entire semiconductor industry with our memory, system LSI, foundry, and LED solutions. Samsung is also leading in the development of the Internet of Things through, among others, our Smart Home and Digital Health initiatives.

Since being established in 1969, Samsung Electronics has grown into one of the worlds leading technology companies, and become recognized as one of the top global brands. Our network now extends across the world, and Samsung takes great pride in the creativity and diversity of its talented people, who drive our growth. To discover more, please visit our official newsroom at (https://news.samsung.com/global/).

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Posted: 2022-05-13 Expires: 2022-06-12

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Tax Director of Controversy and Transfer Pricing

Samsung
Ridgefield Park, NJ 07660

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