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Transfer Pricing Senior Director

Location:
Los Angeles, CA
Salary:
225000
Posted:
March 19, 2024

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Resume:

Andrew Fisher, CPA

San Gabriel, CA 626-***-**** ad4fza@r.postjobfree.com linkedin.com/andrewfishercpa Senior Director of Taxes and Transfer Pricing

Focused, results-driven tax professional with deep expertise in tax strategy, transfer pricing and international tax planning. Strong understanding of U.S. international and domestic tax and a working knowledge of tax systems in many other countries (income tax, VAT/GST and customs).

Well-versed in the nuances of tax controversy, having successfully concluded revenue audits, competent authority proceedings, and Advanced Pricing Agreements (“APA”) involving the U.S., Switzerland, Germany, UK, Japan, Australia and more. Knowledgeable tax expert with a proven track record of developing innovative yet practical solutions for complex business tax problems, working closely with internal and external stakeholders. Applies critical thinking when investigating tax related challenges and opportunities. Works collaboratively with stakeholders to implement solutions. z Areas of Expertise

Data Gathering and Analysis • Tax Planning • Transfer Pricing • Tax Controversy • Tax and Transfer Pricing Records and Reports Tax Compliance • Internal and External Communications • Team Building, Direction, and Leadership • Management of Projects and Tax Operations • Tactical Strategies, Goals, Objectives, and Plans • Effective Policies and Practices z Career Highlights

ü Consistently exceeded objectives, earned top marks on reviews, and garnered praise from colleagues and clients. ü Continually given leadership roles and key initiatives due to outstanding performance. ü Effectively managed a range of tax and transfer pricing activities, often happening concurrently, from start to finish. ü Successfully led tax and transfer pricing teams through complex projects requiring detailed plans, in-depth training, and motivational management.

ü Led project teams to improve intercompany reporting processes and automating quarterly tax provision processes. ü Led the team identifying and analyzing DEMPE functions and alignment with ownership of high value adding intangibles. ü Ensured that all internal eBay transactions were reflected in the provision model through collaboration with the provision team. ü Achieved tax certainty on billions of eBay transactions, created positive relationships with tax authorities, and reduced taxes payable by the company.

ü Eliminated $1M+ of VAT leakage annually for eBay by considering alternate pricing methods to achieve desired outcomes. ü Improved income tax efficiency of supply chains and reduced local customs duty and related VAT costs for clients of Deloitte Tax by identifying alternatives and modifying inter-company agreements. ü Developed strategies, plans, and actions for projects that led to accurate TP documentation for Deloitte Tax clients. ü Credited as an enthusiastic, productive team player who proactively learns new skills and stays calm in changing environments. z Recent Experience and Additional Accomplishments Director of Global Transfer Pricing eBay, Inc. 4/2020 – Present Capably led strategies, plans, teams, initiatives, and operations of the global transfer pricing unit for eBay, Inc., a multi-national Fortune 500 company that brokers customer-to-customer and retail sales through online marketplaces in 190 markets worldwide.

• Responsible for all operational transfer pricing within eBay and maintaining all inter-company agreements.

• Supported tax accounting and reporting processes, including ASC 740 exposures for quarterly and annual financial reporting.

• Developed the strategy for international tax disputes involving multi-million dollar adjustments and lead resolution negotiations with the IRS.

• Presented and explained the company’s global tax strategies, plans, and activities to the incoming CFO.

• Negotiated and concluded APAs in relation to $1B transactions involving Germany, Switzerland, and Australia.

• Resolved multi-million dollar international tax disputes in Italy and Israel.

• Designed and implemented intercompany pricing for a Global Payments System, including intercompany agreements. Andrew Fisher, CPA

Page 2 of 2-626-***-**** ad4fza@r.postjobfree.com linkedin.com/andrewfishercpa

• Researched, selected, and implemented a technology solution for global transfer pricing documentation. z Recent Experience and Additional Accomplishments, Continued Managing Director Deloitte Tax, LLP 12/2007 – 3/2020 Recruited, trained, developed, and managed the team that assisted the large base of clients with understanding and addressing transfer pricing arrangements internally as well as to revenue authorices.

• Designed and implemented changes to a consumer goods supply chain for a U.S.-based MNC that resulted in substantial improvements in operational efficiency while generating income tax and customs duty savings.

• Led teams that delivered numerous global TP documentation projects for U.S.-based multi-national companies, including meeting country-by-country reporting obligations.

• Identified and addressed state income tax transfer pricing risks and opportunities. Made modifications to business processes and workflows and successfully defended the new structure during a revenue authority exam.

• Became the expert in the application of ASC 740 to transfer pricing issues and operation of tax effect accounting issues. z Previous Experience

Experience prior to 2007 includes being a Tax Partner with Deloitte Tax Limited (Deloitte Australia), with a focus on transfer pricing and corporate tax, recruiting and skills development and management of the business. z Education and Professional Qualifications

Master of Taxation Law University of Sydney

Bachelor of Economics (Accountancy Major) Macquarie University Certified Public Accountant State of California

Chartered Accountant Chartered Accountants of Australia and New Zealand z Technology

Strong understanding and frequent use of technology, including Microsoft Office Suite, many types of accounting and tax tools, organization- and industry-specific systems, cloud environments, and web-based applications. z Community Involvement

Active volunteer, include a leadership role as Head Coach of AYSO All Star Teams.



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