Eaton Careers

Tax Counsel - Senior Director Tax Controversy

Cleveland, Ohio


Job Description

Within the finance organization, Eaton has an exciting opportunity for a Tax Counsel and Senior Director, Transfer Pricing Controversy, located at our Beachwood, OH facility.
The Tax Counsel and  Senior Director, Transfer Pricing Controversy works within the Transfer Pricing Strategy Team which supports a worldwide organization.  This position reports directly to the VP, Transfer Pricing Strategy and has matrix reporting to the VP, Federal Tax Strategy, whose team manages the IRS audit.  As Tax Counsel, this individual conducts the legal review and proactively establishes the evidentiary aspects of all tax planning, tax controversy (including high-risk audit issues and administrative appeals), and other compliance matters within the Tax Department on a global basis.  The role also supports the Law Department in all tax litigation matters.
As Tax Counsel and Senior Director, Transfer Pricing Controversy, this individual will play a major role in reducing outside legal fees related to the evaluation of local country rules and global tax policy shifts focused on the taxation of intercompany transactions, which are expected to exponentially increase tax controversy worldwide.  This individual will also be responsible for reviewing all major transfer pricing transaction flows from a tax controversy perspective.
  • You will review all targeted areas of tax audits worldwide.
  • You will provide legal support for Tax Appeals worldwide, including evaluation of hazards of litigation and negotiation of settlements.
  • You will provide support for all Eaton tax litigation globally, including proactive management of the evidentiary aspects of the case, risk evaluation, and participation in field visits by tax authorities.
  • You will review all major tax planning & implementation strategies, including identification and evaluation of potential trial experts at the beginning of the project and review of documentation supporting execution and technical positions.
  • You will be responsible for legal review of tax accounting for uncertain tax positions & evaluations of tax reserves, including input into public filing disclosures.
  • You will evaluate transfer pricing risk worldwide and manage the evidentiary aspects of transfer pricing documentation, including master file, country-by-country report and local file reports.
  • You will develop and manage the transfer pricing controversy team worldwide.
  • You will liaise quarterly with the Law department on all tax related legal matters.
  • You will engage and manage external tax counsel and expert witnesses to defend tax positions in audit, administrative appeals and litigation processes.
  • You will ensure alignment with of transfer pricing positions globally in order to successfully defend and provide consistency in technical analysis/position.


Basic Qualifications:
  • Juris Doctor Degree (J.D.) from an accredited institution is required.
  • Minimum 10 years of legal experience in tax controversy at a major law firm or Fortune 100 company.
  • Must be legally authorized to work in the United States without requiring company sponsorship.
Position Criteria:
  • Outstanding litigation-focused issue and opportunity recognition skills
  • Extensive knowledge of transfer pricing and valuation from a litigation perspective
  • Demonstrated project management skills.  Must have the ability to prioritize and manage multiple projects at the same time, while adhering to strict time deadlines.
  • Excellent interpersonal & relationship building skills, including both oral and written communication skills.
  • Ability to mentor and teach transfer pricing controversy team on global technical issues and trends
  • Enthusiasm to learn, including the ability to research and master a broad array of complex transfer pricing technical topics.
  • Strong ability to influence thinking and gain acceptance of others in sensitive or adversarial situations.
Preferred Qualifications:
  • LLM – Tax is preferred

We make what matters work. Everywhere you look—from the technology and machinery that surrounds us, to the critical services and infrastructure that we depend on every day—you’ll find one thing in common. It all relies on power. That’s why Eaton is dedicated to improving people’s lives and the environment with power management technologies that are more reliable, efficient, safe and sustainable. Because this is what matters. We are confident we can deliver on this promise because of the attributes that our employees embody. We’re ethical, passionate, accountable, efficient, transparent and we’re committed to learning. These values enable us to tackle some of the toughest challenges on the planet, never losing sight of what matters.

Job: Finance/Accounting

Region: North America – US/Puerto Rico
Organization: Corporate Sector

Job Level: Director
Schedule: Full-time
Is remote work (i.e. working from home or another Eaton facility) allowed for this position?: No
Does this position offer relocation?: No
Travel: Yes, 10 % of the Time

Requisition ID: 062059