Senior Manager / Director, Direct Tax & Transfer Pricing
Leads global direct tax and transfer pricing for a hyper-growth ecommerce tech company, managing US federal/state/international compliance, provision (ASC 740), audits, M&A tax support, and tech-driven process improvements. Requires 8+ years Big 4/in-house tax experience and proficiency in complex tax concepts.
About the job
Responsibilities
- Leverage technology to lead all aspects of direct tax matters, partnering with the Head of Tax and external advisors.
- Lead and manage the preparation and review of U.S. federal and state income tax provision (ASC 740), ensuring accuracy on quarterly and annual basis.
- Oversee federal, state and international income tax compliance, coordinating with external advisors and internal stakeholders.
- Serve as subject-matter expert on transfer pricing, maintaining documentation, policies, and intercompany agreements in alignment with IRS regulations, OECD guidelines and local requirements.
- Manage international tax matters, including Subpart F, NCTI, BEAT, FDEEI, and other U.S. international tax implications.
- Oversee U.S. withholding tax obligations (Forms 1042/1042-S) and foreign withholding exposure, partnering with Treasury and Legal.
- Provide proactive audit support for federal, state, and international tax authority examinations.
- Support mergers, acquisitions, and strategic transactions, including tax due diligence, structuring analysis, purchase price allocations, and post-acquisition integration.
- Partner with Finance and Accounting to identify tax-efficient structures and process improvements leveraging technology and AI tools.
- Monitor legislative and regulatory developments and advise leadership.
- Collaborate cross-functionally on ad hoc tax planning and special projects.
Requirements
- 8+ years of income tax experience in a Big 4 public accounting firm and/or in-house corporate tax function.
- Strong technical proficiency in U.S. federal and state income tax provision (ASC 740) and compliance.
- Solid understanding of transfer pricing principles and international tax concepts (Subpart F, GILTI, BEAT, FDII, tax treaties).
- Exposure to tax due diligence and M&A structuring is a strong plus.
- Proficiency with tax technology platforms and strong interest in AI-driven tools and automation.
- Strong analytical, organizational, and communication skills.
Compensation
Target total compensation $170,000 - $228,000, including fixed annual salary of $153,000 - $188,000, employee equity plan grant, and benefits (4% 401K match, premium health insurance, etc.).
Skills
Asc 740, Transfer Pricing, Subpart F, Gilti, Beat, Fdii, Tax Technology, AI Tools, Tax Provision, Income Tax Compliance
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