Transfer Pricing Manager

JOIN THE TEAM THAT’S POWERING PROGRESS

Building cities. Driving commerce. Fueling Progress. For over 100 years, Allison has powered the vehicles and technology that move our world forward.

What powers us? Our employees. From the first person hired by James Allison in 1915 to the thousands across the globe who work for Allison today, we're driving progress everywhere because we employ top talent worldwide. In both the Allison Transmission and Allison Off-Highway Drive and Motion Systems business units, our team strives to Improve the Way the World Works.  

Learn more about this role and how you can begin driving your career forward!

Benefits:

The below list features some of the benefits currently available. Eligibility may be subject to the terms and conditions of governing documents and available benefits may be subject to change at the company’s discretion.

• Choice of medical plans with prescription coverage

• Employer HSA contribution

• Dental & Vision Insurance

• Paid Parental Leave

• Short & Long-Term Disability

• Other voluntary benefits including: Critical Illness, Hospital Indemnity, Identity Theft Protection and Pet Insurance

• 401K with generous Company match & contribution

• Accrued Paid Time Off

• 12 Paid Holidays + 1 Floating Holiday

• Robust employee wellness program

• Tuition assistance program

Job Description:

The Transfer Pricing Manager is a key role within Allison’s tax team that includes responsibilities that support preparation and review of U.S. international income tax calculations and modelling for tax accounting, tax return, and planning purposes. The position is multifaceted and includes monitoring and analysing U.S & foreign regulatory environment, audit controversy, and advising/supporting international restructuring projects.

This position requires comprehensive understanding of U.S. international tax including GILTI (NCTI), BEAT, FDII, Subpart F and foreign tax credit to assist in preparation and review of income tax provisions and tax return filings. 

In addition, this role will oversee Allison’s global transfer pricing processes, including the preparation of financial analysis for intercompany billings, forecasting processes, tax return computations, and support audit defense of Allison’s transfer pricing regime. The position will collect and analyze financial data, prepare clear and well-organized supporting documentation, and work with both internal and external business partners to accomplish these goals.

Key Responsibilities:

• Responsible US International income tax compliance:

• Lead contact with 3rd party external tax provider for ITAX related items:

• GILTI (NCTI), FDII, BEAT, Subpart F, and foreign tax credit

• Communicate with foreign affiliates to capture compliance & provision info

• Review foreign related party US GAAP prepared provisions

• Support/communicate info needed for GloBE Return

• Responsible for OECD/Pillar Two modelling & analysis     

• Monitor various countries OECD Global Min Tax positions

• Support Federal/State quarterly tax estimate preparation w respect to ITAX

• Responsible for Foreign Related Party OECD Transfer Pricing process:

• Lead contact with 3rd party external tax provide to support in maintaining:

• Global Master Report (Mfg/Dist+) & various local files

• Monthly monitoring of operating margins to forecast adjustments

• Mid-year/year-end cost+ adder review and adjustments

• Maintain cost+ Adder Summary & support regional communications

• Research complex tax issues and knowledgably advise management of interpretation and application of tax laws and regulations

• Support audit controversy, including correspondence IRS/State requests.

• Demonstrate solid project management and excellent communication skills while interfacing with management, external advisors, and team members on complex technical topics, initiatives, and special projects.

• Collaborate with internal and external business partners worldwide on international tax matters

• Prepare/review various reports and analyses for internal use by management and external use by taxing authorities

• Maintain various tax calendars

• Identify/implement areas for tax process automation/improvement

Key Performance Measures:

• Effective/timely management of compliance process

• Effective/timely communication with internal/external customers

• Problem solving ability and desire to improve current processes

Qualifications:

• Bachelor’s Degree

• Certified Public Accountant or CPA eligible

Experience:

• Minimum 7 years of overall corporate income tax experience and at least 5 years of US international tax experience

• Extensive knowledge in US International tax laws

• Transfer Pricing experience preferred

• Manufacturing & SAP/large ERP system experience a plus

• Strong analytical, critical thinking skills

• Excellent time management, interpersonal, and communication skills

Scope Factors:

• Forecast, document, and administer intercompany billings, including coordination and communication with internal finance functions

• Understand complexity of US international tax regulations, intercompany sales/COS and managing impact on foreign operating margins related to Transfer Pricing

• Understand complexity of new OECD Global Minimum Tax requirements and impact to overall company tax liability

• Global tax oversight in over 25+ countries

Allison Transmission is an equal opportunity employer. We have opportunities for all qualified applicants regardless of age, race, color, sex, religion, creed, national origin, disability, sexual orientation, gender identity/expression or veteran status.

If you are an individual with a disability or a disabled veteran requiring assistance and/or reasonable accommodations reviewing any of the careers information, please contact us at ati+ask4max@service-now.com.

Please note that Allison Transmission will make an offer of employment only to individuals who have applied for a position using our official application. Be on alert for possible fraudulent offers of employment. Allison Transmission will not solicit money or banking information from applicants.