Seeking a seasoned Global Tax VP to report to a strong CFO. Remote work anywhere in US or Asia. Absolutely requires manufacturing (ideally in Asia) and OECD Pillar Two (GloBE) experience.
Primary Responsibilities:
Global Tax Strategy & Planning • Develop and execute a tax strategy aligned with global supply chain design, IP ownership, and long-term corporate objectives. • Optimize global effective tax rate while maintaining compliance, transparency, and reputational integrity. • Advise leadership on tax implications of strategic initiatives, financing, acquisitions, and geographic expansion. • Support semiconductor R&D, design, and licensing structures through tax-efficient planning.
OECD Pillar Two & Global Minimum Tax
• Lead enterprise implementation and ongoing compliance with OECD Pillar Two (GloBE) rules. • Model jurisdictional effective tax rates and assess top-up tax exposure across operating regions. • Design structural and operational responses to mitigate Pillar Two impacts while preserving commercial flexibility. • Monitor adoption and regulatory guidance across the U.S., EU, China, Singapore, Israel, and other jurisdictions.
Transfer Pricing & Intercompany Structuring
• Design and maintain robust transfer pricing policies consistent with OECD guidelines and local country requirements. • Oversee pricing of intercompany transactions including: o IP licensing and cost sharing o Semiconductor design and engineering services o Contract manufacturing and foundry relationships o Distribution and regional sales support • Ensure contemporaneous documentation, benchmarking, and audit defense readiness. • Manage advance pricing agreements (APAs) and competent authority matters.
Cayman Islands Economic Substance & Governance
• Ensure compliance with Cayman Islands economic substance regulations. • Advise on governance practices, board oversight, and decision-making protocols necessary to maintain substance and tax integrity. • Align operational realities with parent company structure and tax positions.
International Tax Compliance & Risk Management
• Oversee tax compliance, reporting, and risk management across all jurisdictions. • Ensure adherence to U.S. international tax rules, including GILTI, FDII, Subpart F, BEAT, and foreign tax credit optimization. • Monitor tax developments in PRC China, Taiwan, Hong Kong, Singapore, Israel, and Canada. • Lead global tax audit defense and controversy resolution.
Supply Chain & IP Structuring
• Partner with operations, legal, and R&D leadership to align tax planning with semiconductor design, manufacturing, and distribution models. • Advise on tax considerations related to foundry partnerships, packaging/testing operations, and cross-border IP development. • Evaluate incentives and tax credits related to R&D and technology innovation, including Israel and Singapore programs.
Financial Reporting & Governance
• Lead ASC 740 tax accounting, uncertain tax positions, and public disclosures. • Ensure robust internal controls over tax reporting and compliance. • Provide regular reporting to the CFO and Audit Committee on tax risks, exposures, and strategic initiatives. • Manage relationships with external auditors and tax advisors.
Leadership & Team Development
• Build and lead a high-performing global tax organization. • Develop internal expertise aligned with evolving global tax frameworks. • Manage global advisors efficiently and strategically.
Qualifications & Experience
Required
• 20+ years of progressive international tax leadership experience. • Deep expertise in multinational tax structures and cross-border planning. • Demonstrated experience implementing OECD Pillar Two frameworks. • Extensive transfer pricing expertise in IP-intensive industries. • Strong knowledge of Cayman Islands economic substance requirements. • Experience managing tax matters across the U.S., Greater China, Asia-Pacific, Israel, and Canada. • Public company experience and expertise in ASC 740 reporting.
Preferred
• Semiconductor, technology, and IP-driven business experience. • Experience with global R&D structuring and contract manufacturing models. • CPA, JD, or LLM (Taxation) preferred. • Experience with APAs and global tax controversy.
Leadership Competencies
• Strategic and commercially minded. • Ability to translate complex tax regimes into actionable business strategy. • Credible advisor to executive leadership and Board. • Strong governance mindset and risk awareness. • Effective leader in a complex multinational environment.
Strategic Importance of the Role
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