| In this position, the individual will be responsible for transferring price management, US international and foreign tax planning, management of international tax controversies, providing tax leadership in acquisitions, reorganizations, and divestitures with international elements. The individual will evaluate SanDisk's global tax situation and provide advice on international tax planning strategies to optimize results. Within Transfer Price Management, the individual will provide stewardship on global transfer pricing policies and monitor compliance with them, establish and maintain transfer pricing documentation requirements in multiple jurisdictions. The individual will also ensure that inter-company agreements are consistent with SanDisk transfer pricing policies and inter-company transactional relationships, identify local transfer pricing requirements and develop strategies for preparing documentation studies and other support as necessary for penalty avoidance and manage transfer price and other international queries under audit. Within International Tax Planning, the individual will be responsible for analyzing US income tax deferral and withholding tax minimization opportunities, transactional taxes and blending foreign tax credit pools for maximum benefit of dividend remittances. The individual will manage a team that handles international portions of the tax provisions and international compliance. The individual is also responsible for international aspects of the Internal Revenue Service examinations and managing any tax controversies in the international area. The individual through the team will maintain E&P pools for our foreign subsidiaries and international tax compliance including preparation of Forms 5471 and other international forms (e.g.: 926, 1118, 1120-F, 5713, 8821, 8832, 8858, and 8865). Within Sarbanes-Oxley Compliance (404), the individual is responsible for evaluating control procedures necessary to assure compliance with foreign tax requirements by foreign subsidiaries as well as accurate reporting of tax transactions to headquarters. The individual will also be responsible for establishing and monitoring compliance with these control procedures, this includes evaluating financial and tax systems for 404 purposes. Additional duties of the International Tax Director will include overseeing FAS 109 calculations for international transactions and for foreign subsidiaries and affiliates by analyzing local tax positions taken (UTB's and any associated penalties and interest) for FIN 48 purposes; The individual will also be responsible for managing and training the international tax staff on all aspects of tax compliance, research, planning, audit documentation and issue resolution. This position requires a Bachelors degree in Accounting or a law degree (CPA/ Masters in Taxation and/or Bar member/LLM Tax Law strongly preferred). The ideal individual must possess demonstrated organizational, people, process, systems and project management skills. Also, the individual must possess capacity for sustained work on multiple and changing priority projects under tight time frames, strong accounting plus exceptional written and verbal communication skills are required and outstanding leadership skills are essential. The individual must have substantial international tax planning experience, as well as direct experience in managing IRS audit issues past field examinations. SanDisk offers a highly competitive compensation package and great benefits, which include Stock Options, ESPP, matched 401 (K), comprehensive insurance and tuition reimbursement. SanDisk is an equal opportunity employer. |
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