Americas Director Tax Controversy & Assistant Tax Counsel

Employment Type:
Full Time
Job Ref:

The NA tax team is comprised of approx 12 professionals in the US and Canada, and it oversees all areas of US and Canada federal, state, and international income taxes, as well as performing significant transfer pricing and indirect tax (sales/use/commodity/property) functions. The team is accountable for all NA income tax reporting, compliance, risk management, and planning in line with the Global Tax Policy as well as providing tax input to the NA and global business development agenda.
Primary responsibility for federal tax audit and controversy matters including audit planning and strategy, IDR responses, evaluation of proposed adjustments, and management of IRS relationship. Requisite understanding of both NA and global transactions, and other considerations that impact the federal income tax return.
Responsible for strategic guidance and support on significant state and local audits, and Canadian tax audits, as necessary. Utilize practices and tactics from federal audit to drive process and other improvements to state tax audits and Canadian tax audits.
Provide tax support of both NA and global business development and commercial agenda, including M&A.
Group Tax manages the P&L, balance sheet, and cash impacts related to global corporate income and indirect taxes.
Market Complexity
NA market is extremely complex - active in all areas of Diageo global business, including production and distribution, and represents 30 - 40% of global results. Legislative environment is extremely complex and evolving.
Reporting includes approximately 16 management reporting packages, and multiple legal entities, subject to federal, state, provincial and local audits.
Leadership Responsibilities
Responsible to display Diageo Leadership Standard and Diageo Capabilities
Communication and influencing of senior stakeholders across business
Purpose of Role
Primary responsibility for day-to-day management and interaction with the on-site Internal Revenue Service auditors.
Significant role in shaping and supporting U.S. federal and state tax audit strategy, as well as support to Canadian tax audits.
Key tax technical resource for Group Tax and key supporting role for business development, legislative and regulatory monitoring and review, and Group Tax strategy projects.
Top Accountabilities
Lead tax interaction with IRS; develop and implement federal and state tax audit strategy.
Key supporting role in implementation of Group Tax strategy with respect to U.S. tax projects, international tax planning efforts and M&A, as well as transfer pricing matters.
Coordinate and manage complex projects, while influencing global cross-functional stakeholders.
Coordinate with U.S. and global tax compliance team on tax audits.
Support to U.S. state tax audits and Canadian tax audits as needed.
Strong federal tax technical knowledge
Strong legal research and writing
Strong financial modeling and excel skills
Strong tax accounting knowledge
7+ years of corporate tax experience preferred
3-5 years of managing Large Case IRS Audit or equivalent controversy experience
Both corporate and advisory experience preferred
Bachelor's degree in Accounting or Finance preferred
JD, CPA, and/or advanced degree in taxation preferred
Ability to effectively lead, collaborate, and excel in a team oriented environment to optimize the company's tax position.
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