Job Title Senior Director, International Tax

Job details

Job Category	Professional
Location	Racine, WI - Shoop
Division	GLBL - Finance
Job Description	This position reports to the Global Tax Counsel/Vice President – Corporate Tax Counsel and directs all tax planning, compliance reporting, and tax accounting for the company’s foreign income and non-U.S. operations. The International Tax Director (ITD) is responsible for advising executive management on significant international and foreign transactions, including acquisitions, divestitures, reorganizations and financings. The ITD provides and directs tax legal analysis of routine and sophisticated planning, compliance, and audit matters, including development and monitoring of company policies. The ITD has broad decision making authority and responsibility for managing international tax risks and exposures, formulation and implementation of opportunities and corrective actions, identifying process and quality improvements, and managing international tax personnel. The ITD has supervision responsibilities for management level staff consisting of three attorneys and an additional three support staff. The educational background for this position requires a bachelor’s degree in accounting or finance (preferably a CPA), and an advanced post graduate degree (Masters of Tax, JD). The position requires at least 10 years intensive tax experience at a large corporation, major law firm, or a Big 4 or similar major accounting firm, with at least 5 years focused on international taxes. Principle Accountabilities: 1. Maintain broad-based expertise of U.S. tax laws, tax treaties, and proposed legislation relevant to determination of (i) the Company’s Foreign Tax Credits, (ii) the Company’s Foreign Tax Credit Limitation, and (iii) the U.S. tax implications of actual and potential international transactions engaged in by the Company and its foreign subsidiaries, and planning in regard thereto. 2. Maintain general working knowledge of existing and proposed foreign tax laws sufficient to provide advice to management. 3. Analyze and interpret relevant U.S. and international tax laws and tax treaties to minimize worldwide taxes imposed on the operations of the Company and its foreign subsidiaries, including intercompany payments of royalties, regional staff charges, dividends, interest, etc. 4. Counsel U.S. and foreign management on tax aspects of foreign acquisitions, dispositions, and reorganizations, including the structuring of new international subsidiaries or entry into new foreign manufacturing distributor arrangements. 5. Plan, analyze and recommend tax advantaged financing structures for capital/borrowing needs of foreign subsidiaries, and investment of excess U.S. and foreign funds, in order to achieve maximum worldwide tax benefits. 6. Prioritize projects and assign resources to accomplish objectives with the greatest value to the corporation given limited time and resources. 7. In conjunction with the Law Department and International Finance, implement and maintain license, services, and other key agreements between the Company and its international subsidiaries and distributors; and, direct and supervise foreign subsidiaries in obtaining government approvals for payment and/or deductibility of charges under such agreements. 8. Actively monitor and counsel management on tax issues relating to intercompany pricing issues and maintain documentation as required under Internal Revenue Code Sections 482 and 6662 for related-party transactions. 9. Analyze and interpret U.S. tax laws to assure compliance with U.S. tax reporting requirements regarding the operations of, and the transactions conducted by, the Company’s foreign subsidiaries and coordinate tax legislative and regulatory initiatives in the international tax arena. 10. Supervise and review the budget, fall forecast, etc., calculation of U.S. Foreign Tax Credits and Limitation, and tax return calculations and forms (IRS Form 1118) and information returns (IRS Forms 5471 and 5713), as prepared by International Tax Staff. 11. Supervise foreign subsidiaries’ tax audits relating to tax deductions for related-party payments and other significant items and in prosecuting tax appeals relating to such matters, including overseeing tax litigation in foreign jurisdictions. 12. Supervise the handling of U.S. income tax audits dealing with foreign tax issues, including the preparation of responses to international IDR’s, assessing the Company’s position on disputed items, and recommending whether to appeal IRS adjustments. 13. Identify, select, and periodically review foreign tax advisors as required to achieve objectives. 14. Select, develop, and review the international tax staff. 15. Maintain knowledge of accounting for income taxes, recommend and draft financial policies to properly implement accounting standards on income taxes, and provide advice to management regarding the tax accounting aspects of transactions and legislative developments.
Requisition Number	3433BR

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