- Oversee the development and application of global transfer pricing policies and calculations related to cross-border intercompany transactions and business activities.
- Collaborate with internal business partners to ensure tax efficient business decisions are made with respect to cross-border transactions, supply chain planning, import/export activities, choice of legal entity, location of legal entities and employees, etc. to ensure minimization of indirect taxes, withholding taxes, and permanent establishment risk.
- Support M&A transactions and legal entity restructuring projects including pre-acquisition due diligence and post-acquisition IP ownership and integration activities.
- Develop and maintain relationships with cross-functional business partners across Finance, Business Development, Legal, Business Operations, and Human Resources to ensure proactive tax involvement in new business initiatives and operational changes.
- Maintain a deep understanding of Cohu's legal organizational chart, transaction flows, risks, assets, and functions, and advise on the respective intercompany transactions and agreements.
- Perform technical research and analyses for various tax topics including transfer pricing, permanent establishment, tax holiday incentives, tax policy changes, and anti-hybrid and tax avoidance rules, etc.
- Maximize tax efficiencies related to repatriation of cash from foreign subsidiaries and oversee global cash funding requirements and intercompany loans.
- Plan and manage legal entity liquidations/dissolutions; oversee maintenance of the legal entity organization chart.
- Work closely with legal counsel to prepare and/or review intercompany agreements, including sales/service agreements, licenses, loans, and contracts.
- Review transfer pricing documentation, monitor intercompany transactions to ensure compliance with transfer pricing policies, and manage outsourced transfer pricing studies.
- Provide support for foreign tax audit and tax controversy matters including assistance with the preparation of replies to tax authority information requests and calculation of FIN 48 reserves for uncertain tax positions reflected in foreign income tax filings.
- Identify new legislation across the globe, including OECD "Pillar 2" global minimum tax rules, and determine the potential impact to the Company's worldwide operations.
- Bachelor's degree in accounting or closely related field required; Master's degree in Taxation preferred.
- CPA preferred, but not required.
- Combination of private industry and Big 4 background
- 15+ years of corporate tax experience; combination of public accounting and/industry experience, preferably working with multinational public companies engaged in manufacturing.
- 10+ years of recent global tax planning and tax operations experience.
- Strong understanding of U.S. GAAP tax accounting principles under ASC 740 and FIN 48.
- Demonstrated technical understanding of post-TCJA U.S. international tax matters.
- Hands-on experience using Oracle ERP in a multinational manufacturing environment strongly preferred.
- Strong leadership skills including an ability to explain complex tax concepts to other members of the finance team.
- Excellent project management skills and a demonstrated ability to prioritize multiple competing deliverables and meet deadlines under significant time pressure.
- Strong attention to detail with emphasis on accuracy and self-review.
- Proven self-starter with a demonstrated ability to work both independently and in collaboration with team members.
- Strategic thinker and problem solver with history of making decisions that reflect sound business acumen.
- Strong verbal and written communication skills; exhibits confidence in critical communications and the ability to influence both internally and externally.
- Exercises sound judgement in risk-based decision making; exhibits courage in making challenging or unpopular decisions.
- Sensitive to cultural differences and a variety of communication and learning styles.
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Director, of Global Tax Planning - Milpitas, United States - Cohu
Description
Job DescriptionThe Director of Global Tax Planning & Operations has a critical leadership role within Cohu's Tax Department and will report to the Head of Tax. Detailed knowledge of global transfer pricing principles is required, in addition to hands-on experience developing and applying transfer pricing strategies in a fast-paced multinational manufacturing setting. This role is a highly visible one that will have direct contact with the Company's senior leadership team in addition to having significant, frequent interaction with senior members of the tax, accounting, local country finance, and business operations teams. Accordingly, the ability to effectively collaborate with and provide leadership to global teams in remote locations is an essential skill for this role.
This position is remote and allows the incumbent to work from his/her home office. In one of the following states: CA, NY, RI, MA, MN, NJ, TN, TX, IN, FL, PA, IL, NC, NV, AZ, WA.
Essential Functions/Major Responsibilities
Qualifications
About Us
Cohu is a leading supplier of semiconductor test and inspection & metrology handlers, micro-electromechanical system (MEMS) test modules, test contactors, thermal sub-systems and semiconductor automated test equipment used by global semiconductor and electronics manufacturers and semiconductor test subcontractors. Our product portfolio is focused on increasing yield, reducing cost of test, and accelerating time-to-market.
We are the leading supplier of Semiconductor Test and Inspection & Metrology Handlers and Test Contactors. We have market leadership in RF Power Amplifier/Front-End Module Testing.
Cohu is a publicly-traded (NASDAQ: COHU) global company with headquarters in Poway, CA. We have a global footprint with ~3,000 employees. We have product development innovation centers in the US, Germany, and Switzerland, manufacturing sites in the US, the Philippines, Malaysia, and Japan, and worldwide sales & service and administrative teams.
Join our team and help deliver leading-edge solutions to enable a smarter, safer, and more connected future.
About the Team
General & Administrative (G&A)
Local and global resources and expertise in finance & accounting, audit, human resources, legal, compliance, and information technology.
Director, of Global Tax Planning professionals in Milpitas
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Mihir Gandhi
Principal Software Engineering Lead