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Your Role and Responsibilities
IBM is seeking candidates to join its global transfer pricing and valuation practice. Transfer Pricing is a multi-disciplinary specialty engaged in evaluating cross-border intercompany payments and flows, engaging various stakeholders (including tax authorities, IBM finance, IBM intellectual property lawyers, and others within the broader organization), valuation, supply chain analysis and global documentation.
This is a challenging and fast paced position that requires a candidate to understand IBM's complex business structure, liaison with internal and external stakeholders, understand the history of legal agreements and have a working understanding of financial reports used in cross-border inter-company transactions involving flows of goods, services and intangible property.
Take a leadership role in drafting intercompany legal agreements, memorandums, and engage with international tax to understand intercompany flows associated with a given transaction;
Assist in preparing audit analyses, support audit-ready files and draft memoranda/reports, as appropriate;
Take a leadership role for inter-company matters with legal, accounting, financial planning and external reporting foreign controllers, business managers and tax departments;
Be responsible for drafting Transfer Pricing Documentation (including 482 and MasterFile) for all businesses within IBM, review of local files as appropriate;
Interact with tax and business executives, present transfer pricing planning strategies, answer technical questions, intercompany legal agreement/structuring questions, or other business information required for transfer pricing studies; and
Have a working knowledge for developing financial models to evaluate audit risks and opportunities for transfer pricing projects.
Required Technical and Professional Expertise
JD, LLM or a Master's Degree in Taxation and/or CPA (or equivalent)
At least 6 years of experience in Transfer Pricing
Demonstrate ability to work both autonomously and in a team environment
Strong writing skills and focus on details
Strong analytical skills and experience with MS Word, PPT, and Excel
Excellent time management, communication (verbal and written), decision-making, presentation, interpersonal and organizational skills
Preferred Technical and Professional Expertise
About Business UnitThe IBM Finance organization is responsible for driving enterprise performance and transformation. We are the financial stewards of IBM, delivering IBM's financial strategy, developing new business models, and mitigating enterprise risk. Do you have a passion for creating business value? Join our team in accounting, financial planning, pricing, business controls, tax, treasury, business development (acquisitions & divestitures), and global financing.
Your Life @ IBMWhat matters to you when you're looking for your next career challenge?
Maybe you want to get involved in work that really changes the world? What about somewhere with incredible and diverse career and development opportunities - where you can truly discover your passion? Are you looking for a culture of openness, collaboration and trust - where everyone has a voice? What about all of these? If so, then IBM could be your next career challenge. Join us, not to do something better, but to attempt things you never thought possible.
Impact. Inclusion. Infinite Experiences. Do your best work ever.
About IBMIBM's greatest invention is the IBMer. We believe that progress is made through progressive thinking, progressive leadership, progressive policy and progressive action. IBMers believe that the application of intelligence, reason and science can improve business, society and the human condition. Restlessly reinventing since 1911, we are the largest technology and consulting employer in the world, with more than 380,000 IBMers serving clients in 170 countries.
Location StatementIBM will not be providing visa sponsorship for this position now or in the future. Therefore, in order to be considered for this position, you must have the ability to work without a need for current or future visa sponsorship.
IBM intends this job to be performed entirely outside of Colorado.
Being You @ IBMIBM is committed to creating a diverse environment and is proud to be an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, gender, gender identity or expression, sexual orientation, national origin, genetics, pregnancy, disability, age, veteran status, or other characteristics. IBM is also committed to compliance with all fair employment practices regarding citizenship and immigration status.