Position Summary

Deloitte Tax LLP seeks a Tax Manager in San Jose, CA.

Work You'll Do

Help client management understand, plan for, and deal with the complex and dynamic issues surrounding transfer pricing. Work with Ph.D. economists, attorneys, and tax specialists to analyze and resolve international tax and finance issues faced by multinational corporations. Plan and provide guidance for multiple tax engagements, as well as offer expertise to provide multinational clients with professional economic analytical services. Oversee research of complex tax issues and ensure their resolution by subordinate professional accountants, including Tax Seniors. Oversee the preparation and review of complex transfer pricing reports. Formulate tax planning strategies utilizing accounting methods and periods, capital transactions, corporate taxation, and IRS practice and procedures. Determine the potential impact of such developments on client business. Devise and execute database searches for companies in the U.S. and foreign markets. Responsible for incorporating financial information into a standard financial model and conducting economic, financial and accounting analyses. Supervise assignments by Consultants and Seniors in the group and hold responsibility for the development and motivation of engagement staff by providing them with leadership, counseling and career guidance.

• Bachelor's (or higher) degree in Accounting, Finance Economics, Business Administration, or related field (willing to accept foreign education equivalent, including three-year foreign degree).
• Four years as Tax Manager or related occupation gaining experience preparing U.S. and foreign transfer pricing reports documenting intercompany transactions for various multinational companies.
• Experience must include four years of:
  • Reviewing technical aspects of the regulatory framework of transfer pricing documentation and consulting work;
  • Analyzing U.S. regulations and their OECD counterparts governing intangibles and cost-sharing;
  • Utilizing tax research tools and transfer pricing databases, including Compustat, Bureauvan Dijk (Osiris and Amadeus), RoyaltyStat, S&P Capital IQ, and Thomson Reuters ONESOURCE, and statistical software, including MS Excel, designed to conduct transfer pricing analysis;
  • Applying new regulatory principles and guidelines under OECD's Base Erosion and Profit Shifting (BEPS) initiative, preparing country-by-country reports, functional modules, Masterfile to document client's global business structure, and the functional and risk related information;
  • Performing quarterly ASC 740 reviews on transfer pricing reserves, preparing audits, and reviewing workpapers and memos;
  • Utilizing various economic modeling methods, including discounted cash flow, realistic alternatives, income, residual profits, services costs, and other relevant methods as described in the U.S. transfer pricing regulations under IRC 482 and their OECD counterparts, to perform valuation of intangible/tangible assets in the context of transfer pricing;
  • Analyzing U.S. regulations and their OECD counterparts governing intangibles and cost-sharing; and
  • Performing intercompany loan pricing and calculation of de-levered discount rates to conduct intercompany transfer pricing analysis.
• Experience must include two years of:
  • Performing strategic transfer pricing planning, service cost allocation and audit defense; and
  • Mentoring and coaching junior team members and performing activities including assigning tasks, performing quality control, reviewing projects, and conducting comparable controlled transaction analyses.
• Salary: $126,630.00 - $235,170.00/year