Senior Manager - US Transfer Pricing
Core
Lead US-based transfer pricing operations and transactional planning for a global commerce company, embedding policies into high-volume systems and supporting international tax strategies.
Role type
Senior Manager, Transfer Pricing & International Tax Planning
Builds
Defensible tax positions, operational transfer pricing frameworks, and global compliance documentation for intercompany transactions.
Domain
International Tax / Transfer Pricing / Technology
Required skills
US transfer pricing regulations (IRC Section 482), OECD Transfer Pricing Guidelines, transactional planning, intercompany agreements, financial modeling, data management, APA/MAP representation, Big 4 advisory management, ASC 740/FIN 48 analysis
Preferred skills
Master's degree, CPA, JD, in-house tech sector experience, process automation, stakeholder management, strategic thought partnership
Technologies
None explicitly stated
Responsibilities
Lead transactional planning and operational transfer pricing for intercompany transactions; Partner with global teams to scale frameworks and ensure audit readiness; Lead strategies for tangible assets, services, and IP (DEMPE analyses); Represent company in tax authority audits, APAs, and MAP matters; Manage external Big 4 advisors for documentation and benchmarking; Support international tax planning, restructuring, and financial reporting workflows (20% of time)
Seniority
Senior Manager, hands-on IC with leadership responsibilities
