Deloitte Tax LLP seeks a Tax Manager in New York, New York.

Work You’ll Do
Help develop transfer pricing strategies, audit defense, and documentation to cover the spectrum of transfer pricing issues. Employ a multi-national and multi-jurisdictional team, utilizing the latest technology and strategies, to help clients work with complex and dynamic issues surrounding transfer pricing needs. Work with Ph.D. economists, attorneys and tax specialists to analyze and resolve global tax and finance issues faced by multinational corporations. Devise and execute database searches for companies in the US and foreign markets. Incorporate financial information into a proprietary financial model and conducting economic, financial and accounting analyses. Supervise assignments by Consultants and Senior Consultants in the group, and the development, training and motivation of engagement staff by providing them with leadership, counseling and career guidance.

Requirements
Bachelor's degree in any field (willing to accept foreign education equivalent, including a 3-year foreign degree) plus (4) years of experience as a Tax Manager or a related occupation gaining experience preparing and reviewing U.S. and foreign transfer pricing reports documenting intercompany transactions for various multinational companies.

Experience must include four (4) years of:

• Analyzing and reviewing technical aspects of the U.S. regulations and OECD guidelines to assist companies with assessing and applying the transfer pricing rules governing tangible and intangibles intercompany transactions, cost-sharing arrangements and intercompany financial transactions to assist clients with their transfer pricing;
• Writing transfer pricing reports in accordance with the OECD guidelines and reviewing transfer pricing reports for global tax compliance in accordance with IRC 482 and OECD guidelines;
• Performing strategic transfer pricing planning assessment and implementation projects including transfer pricing reviews, value chain alignment projects, valuations, restructuring projects, service cost allocations, audit defense, and advance pricing agreement negotiation with tax authorities;
• Utilizing various economic modeling methods, including discounted cash flows, market capitalization, EBITDA multiple, cost replacement and other relevant methods as described in the U.S. transfer pricing regulations under IRC 482 and their OECD counterparts, to perform valuations of intangible/tangible assets in the context of transfer pricing planning projects;
• Utilizing and reviewing output from tax research tools, including Bloomberg terminal and LexisNexis, transfer pricing databases, including Compustat, Bureau van Dijk (Osiris and Orbis), RoyaltyStat, S&P Capital IQ, Thompson Reuter’s ONESOURCE, Kroll Cost of Capital Navigator, and IBIS World, and statistical software, including MS Excel, designed to conduct transfer pricing analysis;
• Applying regulatory principles and guidelines under OECD's Base Erosion and Profit Shifting (BEPS) initiative, to assist companies with preparing country-by-country reports, functional analysis modules, Local Files and Master Files to document client's global business structure, and the functional and risk related information;
• Assisting cross-functionally for clients across multiple industries, including financial services, corporate and private equity clients, with due diligence, transaction structuring, tax insurance planning and post-merger integration work across the merger and acquisition (M&A) lifecycle as it relates to transfer pricing and international tax;
• Interacting directly with senior management of the transfer pricing team, other tax teams and clients to discuss issue resolution and continuity; and
• Assisting with supervising projects across the full lifecycle of transfer pricing engagements, including proposals, staffing, budgeting, training and closing out projects.

Approximately 10% domestic travel required.

Other
Hours: M-F, 40 hours/week;
Annual Salary: $142,646.00 - $235,170.00

If offered employment, must have legal right to work in U.S. EOE, including disability/veterans.