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Tag Archive for transfer pricing

Senior Tax Manager/Transfer Pricing And International (New Jersey)

Senior Tax Manager- Transfer Pricing New Jersey

Responsibilities involve a wide range of international tax matters including transfer pricing, international aspects of consolidated income tax provision, and international elements of US tax compliance. Coordinate with international finance organization regarding international audits, income tax and transaction tax compliance.  Role is responsible for providing technical tax leadership, with an emphasis on transfer pricing and international tax. Position is responsible for transfer pricing and international tax matters for the Americas consolidated group including preparation and/or review of international portions of the consolidated tax provision, preparation and/or review of international reporting requirements for the US consolidated return. Read more

US Tax Reform As A Chess Puzzle

Kathrine Kimball, Tax Advisor

Co-Authors: John S. MacArthur and Dale A. Spiegel, Jr.

As with global tax strategists, chess players routinely practice against hypothetical opponents to prepare themselves for real contests. Now is the time for the tax community (“taxpayers” below) to similarly prepare for US tax reform (“USTR”).

Taxpayers (White) must act now not knowing what taxing authorities (Black) will do next. Some rules (e.g. BEPS (the OECD Base Erosion and Profit Shifting counter-measures)) are known. Some Black moves (e.g. BEPS implementation) may be anticipated with some reliability. Other potential Black gambits (e.g. the course of US tax reform) are more speculative as of this writing. Chess puzzles often allow White to make a “forcing move” that compels Black’s doom, or perhaps at least allow White to protect itself from defeat by finding a stalemate. Taxpayers moving today do not have that option – all they can do is position themselves as far as possible to achieve favorable outcomes under the most likely variety of taxing authority moves.

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An Interview With A Tax Luminary – Eric Ryan

This is part of the series of interviews I am conducting of highly respected tax experts and luminaries in Silicon Valley. Many of them will be speaking at the 2017 TEI – High Tech Tax Institute Conference in November. Eric Ryan is one such Silicon Valley tax luminary who was also responsible for receiving the world’s first Bilateral Advanced Pricing Agreement (U.S. – Australia). I know of Eric Ryan’s professional accomplishments since Apple Computer retained me to find him many years ago. Eric Ryan was formerly the Head of Tax at Apple Computer, a National Tax Partner/Transfer Pricing with PWC and is an international Tax Lawyer with DLA Piper, Palo Alto, CA. He understands the world of tax from all perspectives.

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TaxConnections Search – Tax Jobs Available!

Our executive search services division conducts highly specialized retained search for a sophisticated clientele. The tax opportunities listed below are some of the projects we currently have available and do not include all of our retained search projects. Many of the senior level searches we conduct are highly confidential and clients request absolute anonymity.

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IRS Transfer Pricing Audit Roadmap

Tom Kerester

Last month, the IRS updated its Transfer Pricing Audit Roadmap in recognition of the strategic importance of transfer pricing.

The IRS transfer pricing specialists in Transfer Pricing Operations (TPO) developed the Roadmap to provide the transfer pricing practitioner, whether employed in TPO or International Business Compliance (IBC), with audit techniques and tools to assist with the planning, execution and resolution of transfer pricing examinations.

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TaxConnections Executive Search – Tax Jobs Available!

Our executive search services division conducts highly specialized retained search for a sophisticated clientele. The tax opportunities listed below are some of the projects we currently have available and do not include all of our retained search projects. Many of the senior level searches we conduct are highly confidential and clients request absolute anonymity.

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TaxConnections – Check Out Our Job Board

Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Search For Tax Jobs At TaxConnections

Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Look At The TaxConnections Job Listings!

Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Looking For A New Tax Job? TaxConnections Is Here To Help!

Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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OECD Updates BEPS Financial Payments And Tax Treaties

William Byrnes

The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.

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Tax Jobs Sponsored By TaxConnections

Tax jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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