Tax Counsel - Senior Director Tax Controversy
- 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.
- 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.
- 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.
- 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.
Region: North America – US/Puerto Rico
Organization: Corporate Sector
Job Level: Director
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