Tax Controversy Position – IBM

Job Description

Introduction
At IBM, work is more than a job – it’s a calling: To build. To design. To code. To consult. To think along with clients and sell. To make markets. To invent. To collaborate. Not just to do something better, but to attempt things you’ve never thought possible. Are you ready to lead in this new era of technology and solve some of the world’s most challenging problems? If so, lets talk.

Your Role and Responsibilities
IBM is seeking individuals with an MBA/MS/MA with focus on finance and economics, with a minimum of 7 to 10 years of transfer pricing experience with a large accounting or consulting firm or multinational company, including supporting transfer pricing disputes.

This position requires significant project management skills. The candidate will have a leadership role within a global team responsible for planning, pricing, documenting and defending IBM’s intercompany transactions in such areas as cost sharing, intellectual property migration, intercompany licensing and hardware pricing.

Required Technical and Professional Expertise
Specific responsibilities include:
• Lead transfer pricing projects to successful completion.
• Work with complex data residing in multiple systems such as planning, accounting and internal measurement systems.
• Develop financial models to defend prices, royalty rates and other cross-border charges
• Plan, coordinate, and implement U.S. and local country transfer pricing studies and strategies that revolve around fact gathering and economic analyses.
• Interact with tax and business executives, present transfer pricing planning strategies, answer technical questions, and gather data and other business information required for transfer pricing studies.
• Accumulate data required to be included in the contemporaneous Transfer Pricing documentation required by Section 6662 of the Internal Revenue Code.
• Take a leadership role for inter-company matters with accounting, financial planning and external reporting foreign controllers, business managers and tax departments.
• Oversee/Develop financial models to evaluate audit risks and opportunities for transfer pricing planning projects.
• Participate in both US and non-US audits by preparing supporting data documentations to defend amounts reported in the US tax return as well as non-US tax and regulatory compliance.
• Demonstrate ability to work both autonomously and in a team environment

Preferred Technical and Professional Expertise
This position requires broad background in transfer pricing including policy work, planning, compliance and audit. Candidates must have strong project management skills and written and verbal communications skills for interface at high level of organization.
• Experience working in an organization with a significant R&D environment, a multiple IP ownership structure and material inter-company royalties a plus
• Strong analytical skills and focus on detail
• Solid background in accounting and financial analysis, as well as sound understanding of business models, P&L, and balance sheet.

CPA a plus