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Manager, Tax Counsel Transfer Pricing

Apply Now Apply Later Job ID 716240BR Location Glendale, California, United States Business The Walt Disney Company (Corporate) Date posted Nov. 04, 2019

Job Summary:

Disney’s Tax Counsel group consists of tax attorneys who provide tax legal advice in connection with various aspects of the Company’s day-to-day operations and contemplated transactions. This includes supporting operations of the Company’s business units such as Studio, Media, Parks Experiences and Products, and Direct-to-Consumer and International. Other group responsibilities include providing tax legal advice in connection with tax audits, appeals, litigation, and transfer pricing matters, and supporting implementation of tax planning and restructuring initiatives.

This role in particular will support Tax Counsel – Transfer Pricing, whose focus is on tax planning and tax risk management for the Company’s transfer pricing matters worldwide. This includes, for example, proactively managing transfer pricing risk by negotiating inter-governmental advance pricing agreements („APAs”) and participating in other governmental programs designed to proactively address transfer pricing issues; providing advice in connection with transfer pricing audits, appeals and litigation to ensure timely and efficient resolution; drafting transfer pricing related governmental submissions; supporting the Disney legal team in drafting intercompany licenses and other intercompany agreements; and providing advice and analysis with respect to the Company’s transfer-pricing related tax reserves. This role will support Tax Counsel – Transfer Pricing in achieving these goals.

Responsibilities:

  • Support Tax Counsel – Transfer Pricing in proactively managing transfer pricing risk by utilizing available resources to obtain advance tax certainty, such as advance pricing agreements, tax rulings, pre-filing agreements, OECD’s International Compliance Assurance Programme etc.
  • In connection with the above, draft governmental submissions, presentations, and responses to tax authority information requests; perform research on tax legal and procedural issues and recommend appropriate courses of action; assist with data collection and data analysis.
  • Assist Tax Counsel – Transfer Pricing in managing transfer pricing disputes with U.S. tax authorities including data collection and drafting IDR responses; support international tax desks in connection with local country transfer pricing audits, appeals, and litigation.
  • Assist with application and management of mutual agreement procedure (“MAP”) cases under tax treaties to address potential double taxation.
  • Draft intercompany IP licenses, service agreements and other intercompany documentation to ensure that intercompany transactions are properly documented and that the intercompany compensation arrangements reflected in such documentation are consistent with the Company’s transfer pricing policies.
  • Provide research and analysis and draft documentation to support the Company’s transfer pricing related ASC 740-10 (FIN 48) reserves.
  • Support other tax functions with regard to transfer pricing matters, e.g. tax compliance and tax planning; collaborate with stakeholders in non-tax roles such as legal, finance, accounting, and intercompany transaction support team.

Basic Qualifications:

  • 6 – 10 years of work experience in a tax department of a multinational corporation, or equivalent experience at a Big 4 accounting firm or law firm, focused on transfer pricing matters.
  • Advanced tax research skills using online and print sources (Lexis, BNA, CCH, etc.).
  • Advanced writing skills including legal memo drafting and government submission drafting.
  • Experience with legal contract drafting, e.g. IP licenses, service agreements, etc.
  • Advanced quantitative modeling and data skills, including Excel.
  • Familiarity with income tax accounting (ASC 740-10) and experience with performing analysis for uncertain tax positions.
  • Ability to communicate complex concepts clearly verbally and in writing.
  • Ability to manage multiple projects and priorities.

Preferred Qualifications:

  • Valuation experience.
  • International tax experience.

Required Education

  • BA/BS Economics, Accounting, Business, Finance or other similar field.
  • Law Degree and admission to a state bar (with membership in good standing).

Preferred Education

  • Master’s in Tax and/or Accounting.
  • CPA certification

About The Walt Disney Company (Corporate):

At Disney Corporate you can see how the businesses behind the Company’s powerful brands come together to create the most innovative, far-reaching and admired entertainment company in the world. As a member of a corporate team, you’ll work with world-class leaders driving the strategies that keep The Walt Disney Company at the leading edge of entertainment. See and be seen by other innovative thinkers as you enable the greatest storytellers in the world to create memories for millions of families around the globe.

About The Walt Disney Company:

The Walt Disney Company, together with its subsidiaries and affiliates, is a leading diversified international family entertainment and media enterprise with the following business segments: media networks, parks and resorts, studio entertainment, consumer products and interactive media. From humble beginnings as a cartoon studio in the 1920s to its preeminent name in the entertainment industry today, Disney proudly continues its legacy of creating world-class stories and experiences for every member of the family. Disney’s stories, characters and experiences reach consumers and guests from every corner of the globe. With operations in more than 40 countries, our employees and cast members work together to create entertainment experiences that are both universally and locally cherished.

This position is with Disney Financial Services, LLC, which is part of a business segment we call The Walt Disney Company (Corporate).

Disney Financial Services, LLC is an equal opportunity employer. Applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, sexual orientation, gender identity, disability or protected veteran status. Disney fosters a business culture where ideas and decisions from all people help us grow, innovate, create the best stories and be relevant in a rapidly changing world.

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