Position Purpose & Summary
The Global Tax & Customs function employs approximately 225 professionals. The function is headquartered in Wayzata, Minnesota. Other tax professionals are located throughout the world with principal offices in Sao Paulo, Buenos Aires, Amsterdam, London, Singapore, and Shanghai.
The Tax Counsel will be a member of Cargill's global tax planning team and will have specific, assigned responsibilities for tax planning. Responsibilities will include capital and legal entity structuring, mergers and acquisitions, joint ventures and dispositions. In addition, the Tax Counsel will be responsible for reviewing and handling a broad spectrum of U.S. tax planning issues for the ongoing operations of the businesses depending on the needs of the department. The Tax Counsel also will be responsible for coordinating advice and strategies with other members of the global tax and customs function.
Key responsibilities will include:
- 60% Tax planning: tax planning entails issue identification, development of alternative solutions, recommendation to business unit and functions, assistance with implementation, and (if necessary) post-implementation review.
- Play a key role in the company's strategic tax planning and initiate and implement high value tax strategies.
- Identify opportunities to optimize the company's foreign tax position, while coordinating with US tax issues.
- Facilitate and manage the tax forecasting process, including multi-year planning
- Manage and communicate forecasting scenarios based on business needs and requests from senior leadership
- Work closely with peers' group to monitor legislative and regulatory developments, as well as company initiatives, and incorporate into forecasting process
- Partner and influence other leaders within Cargill Global Tax to build and maintain an effective tax infrastructure
- Manage relationships with clients and business associates
- Provide tax planning and tax research consulting services
- 25% Tax controversies: assist with development of legal arguments and management of external resources in connection with audits and litigation.
- Partner with local country finance teams on foreign audits to resolve foreign tax controversies
- Foster continuous improvement, technical expertise, and best practices and processes
- 10% Tax reporting, US GAAP tax reporting and compliance: provide legal advice to the U.S. tax compliance groups regarding reporting issues and also to US GAAP tax accounting group.
- 5% Tax training: provide training to business units and functions on key tax initiatives and policies.
Education, Experience, Skills
- Must possess a Juris Doctor
- 5+ years of tax planning experience with a major law firm or Big Four public accounting firm
- Experience demonstrating a practical and technical understanding of the U.S. tax rules applicable to business transactions and mergers, acquisitions, and dispositions
- Ability to identify and resolve tax issues with limited input from senior team members or third party advisors
- Writing skills acquired through legal training as well as work on I.R.S. rulings, appeals and/or litigation or foreign controversies
- Experience in one or more of the following tax sub-specialties: taxation of partnerships, financial products, international tax (BEAT, GLTI, Subpart F)income tax accounting and tax procedure
- JD with honors from top-25 law school
MBA or other degree in quantitative area will be highly desired (e.g., mathematics, economics, or finance)