Senior Director, Global Tax Planning & Controversy

Responsibilities

• Develop and execute global tax planning strategies aligned with business objectives, financial priorities, and risk tolerance.
• Lead international tax planning for cross-border legal-entity structures, intellectual-property arrangements, intercompany transactions, financing, capital deployment, cash repatriation, and operating-model changes.
• Own U.S. federal and state income tax planning, including consolidated returns, financing transactions, tax attributes, nexus and apportionment, sourcing, filing methodology, and entity structure.
• Analyze tax implications of product launches, product changes, and new market expansion; advise the business on practical alternatives.
• Monitor U.S. and international legislative, regulatory, administrative, judicial, and policy developments and address related risks and opportunities.
• Lead tax matters for domestic and cross-border acquisitions, dispositions, investments, joint ventures, partnerships, reorganizations, and other corporate transactions, from evaluation through tax-return implementation.
• Partner with Corporate Development and Legal on transaction negotiations and tax provisions in agreements, including representations, covenants, indemnities, purchase-price provisions, and withholding obligations.
• Own direct-tax controversy strategy across federal, state, local, and foreign income-tax examinations, appeals, competent-authority proceedings, settlements, and resolutions.
• Represent the company before U.S. and foreign tax authorities and develop audit-defense and dispute-resolution strategies supported by technical analysis, documentation, and quantitative modeling.
• Partner with Tax Reporting & Compliance, Legal, Corporate Development, Treasury, Accounting, FP&A, Product, People, Government Relations, and business leadership.
• Ensure tax planning, transaction structures, uncertain tax positions, and audit resolutions are reflected in tax provisions, financial disclosures, and tax returns.

Requirements

• 15+ years of multinational corporate income-tax experience covering global tax planning, M&A, and tax controversy.
• In-house tax experience at a publicly traded multinational company.
• Deep U.S. international tax expertise, including cross-border tax, foreign tax credits, treaties, withholding, permanent establishment, financing, and transfer pricing.
• Deep U.S. federal corporate-tax knowledge, including Subchapter C, consolidated returns, reorganizations, financing transactions, and attribute limitations.
• Experience developing and executing sophisticated tax-planning strategies and leading domestic and cross-border transactions end-to-end.
• Experience negotiating tax terms and developing negotiation positions.
• Experience managing significant U.S. and foreign income-tax audits and resolving disputes with tax authorities.
• Strong research, modeling, and technical-writing skills, sound judgment, executive presence, and experience building high-performing teams.

Nice to Have

• Big Four accounting-firm experience combined with substantial in-house public-company experience.
• MS in Taxation, JD/LLM in Taxation, CPA, or comparable credentials.
• Experience in technology, payments, fintech, digital assets, or another highly regulated industry.
• Experience with capital markets, global cash pooling, intercompany lending, debt restructurings, or capital allocation.
• Experience partnering with government-relations or tax-policy teams.
• Experience applying tax technology, analytics, or AI to analysis, modeling, and audit readiness.