Senior Director, Global Tax Planning & Controversy

Overview

This role leads global tax planning and direct tax controversy for the organization, reporting to the Chief Accounting Officer. Responsibilities span international tax, transfer pricing, U.S. federal and state income tax planning, tax aspects of major transactions, and management of significant tax examinations and disputes. The position also shapes global legal-entity, financing, IP, and operating structures and translates complex tax concepts into practical business solutions.

Responsibilities

• Develop and execute global tax planning strategies aligned with business objectives, financial priorities, and risk tolerance.
  • Identify opportunities, evaluate alternatives, and lead implementation of sustainable, defensible domestic and international tax planning.
• Lead international tax planning for global operations, including:
  • Cross-border legal-entity structures
  • Intellectual-property arrangements
  • Intercompany transactions
  • Financing, capital deployment, cash repatriation
  • Operating-model changes
• Advise on complex U.S. international and foreign tax matters, including:
  • Foreign tax credits
  • Tax treaties
  • Withholding taxes
  • Permanent-establishment considerations
  • Transfer pricing
  • Global minimum tax regimes
• Own U.S. federal and state income tax planning, including:
  • Consolidated return matters
  • Financing transactions
  • Preservation and use of tax attributes
  • Nexus and apportionment planning
  • Sourcing positions
  • Filing methodology and entity structure
• Analyze tax considerations for new product launches, product modifications, and new market entry or expansion efforts.
  • Serve as a thought partner to develop alternative solutions supporting business initiatives.
• Monitor U.S. and international legislative, regulatory, administrative, judicial, and policy developments.
  • Assess impact on global structure, cash taxes, effective tax rate, financial reporting, and compliance obligations.
  • Develop strategies to address material risks and opportunities.
• Lead tax aspects of domestic and cross-border acquisitions, dispositions, investments, joint ventures, strategic partnerships, reorganizations, and other corporate transactions.
  • Cover the full cycle: initial evaluation, due diligence, structuring, modeling, negotiation, closing, integration, and tax return implementation.
  • Develop and evaluate alternative transaction structures.
  • Advise senior leadership on cash-tax consequences, effective-tax-rate implications, use of tax attributes, and potential controversy risks.
• Partner with Corporate Development and Legal on transaction negotiations.
  • Review, draft, and negotiate tax provisions in purchase agreements, investment agreements, commercial contracts, and other transaction documents, including:
    • Tax representations
    • Covenants
    • Indemnities
    • Purchase-price provisions
    • Withholding obligations
    • Allocation of pre- and post-closing taxes
• Own direct tax controversy strategy across federal, state, local, and foreign income tax examinations.
  • Manage the full lifecycle: audit readiness and risk assessment through information-document requests, administrative appeals, competent-authority proceedings, settlement negotiations, and final resolution.
  • Develop strategies for international tax controversies, including transfer-pricing disputes, permanent-establishment matters, withholding-tax disputes, and treaty-based disputes.
• Serve as a senior representative with U.S. and foreign tax authorities.
  • Develop audit-defense and dispute-resolution strategies supported by technical analysis, contemporaneous documentation, and quantitative modeling.
• Partner cross-functionally with Tax Reporting & Compliance, Legal, Corporate Development, Treasury, Accounting, FP&A, Product, People, Government Relations, and business leadership.
  • Ensure domestic and international tax considerations are incorporated early in strategic and operational decision-making.
  • Ensure planning, transaction structures, uncertain tax positions, and audit resolutions are accurately reflected in the tax provision, financial statement disclosures, and filed tax returns through close partnership with Tax Reporting & Compliance.

Requirements

• 15+ years of multinational corporate income tax experience across complex global tax planning, M&A, and tax controversy.
• In-house tax experience at a publicly traded multinational, advising senior executives and cross-functional partners on material tax matters.
• Deep U.S. international tax expertise, including:
  • Cross-border tax
  • Foreign tax credits
  • Treaties
  • Withholding
  • Permanent establishment
  • Cross-border financing
  • Transfer pricing
• Deep U.S. federal corporate tax knowledge, including:
  • Subchapter C
  • Consolidated returns
  • Reorganizations
  • Financing transactions
  • Attribute limitation rules
• Demonstrated success developing and executing sophisticated tax-planning strategies and leading domestic and cross-border transactions end-to-end.
  • Includes negotiating tax terms and developing negotiation positions.
• Proven ability managing significant U.S. and foreign income tax audits.
  • Ability to develop defensible technical positions and resolve disputes with tax authorities.
• Strong research, modeling, and technical-writing skills, with sound judgment in areas of uncertainty.
• Executive presence and proven track record of building high-performing teams.

Preferred Qualifications

• Big Four accounting firm experience in addition to substantial in-house public-company experience.
• MS in Taxation, JD/LLM in Taxation, CPA, or comparable credentials.
• Background in technology, payments, fintech, digital assets, or another highly regulated industry.
• Experience with Treasury initiatives such as:
  • Capital markets
  • Global cash pooling
  • Intercompany lending
  • Debt restructurings
  • Capital allocation
• Experience partnering with government relations or tax-policy teams.
• Experience applying tax technology, analytics, and AI to analysis, modeling, and audit readiness.

Compensation & Benefits

• Pay is market-based and may vary depending on location.
• U.S. locations are categorized into four zones based on a cost of labor index.
• Starting pay range (Zones A–D):
  • $251,600—$377,400 USD
• Benefits include:
  • Remote work
  • Medical insurance
  • Flexible time off
  • Retirement savings plans
  • Modern family planning

Location

• U.S. role (pay varies by U.S. location zone). Final starting pay will be determined based on job-related skills, experience, qualifications, work location, and market conditions.