VP Global Tax

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.

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