Tax Professional - Global Transfer

Tax Professional - Global Transfer Pricing, IBM Corporation, Armonk, NY (Up to 40% telecommuting permitted): Draft intercompany legal agreements, memorandums, and collaborate with various stakeholders to understand intercompany flows related to transactions. Integrate intercompany matters with legal, accounting, financial planning, and external reporting functions, including coordination with foreign controllers. Engage with tax and business executives to present transfer pricing planning strategies, answer technical and intercompany legal agreement and structuring questions, and provide necessary business information for transfer pricing studies. Prepare Transfer Pricing Documentation (including 482 and MasterFile) for all businesses within the company and review local files as appropriate. Assist in preparing audit analyses, support audit-ready files and draft memoranda/reports. Utilize: Contract and Legal writing, Tax Controversy and Litigation knowledge, Tax Planning Advisory, Corporate/Cross-border Transactions knowledge. Required: Bachelor's degree or equivalent in Taxation, Law, Legal Studies or related and five (5) years of experience as a Tax Advisor or related. Five (5) years of experience must include utilizing Contract and Legal writing, Tax Controversy and Litigation knowledge, Tax Planning Advisory, Corporate/Cross-border Transactions knowledge. $153924 to $180000 per year. Please send resumes to recruitad@us.ibm.com. Applicants must reference H207 in the subject line.