Senior Analyst, Tax Controversy & Transfer Pricing

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Location: Los Gatos or Los Angeles, CA

* Please note* we will start reviewing applications and reaching out to candidates in January 2026.

Are you seeking a role that offers opportunities for growth in global tax controversy, with a particular focus on transfer pricing controversies? Are you interested in working with global taxing authorities? Do you enjoy analyzing complex technical issues, the intersection of quantitative analysis and law, and working with cross‑functional partners to help navigate the changing world of tax controversy? We’d love to speak with you!

Our global tax controversy team serves a central part in the success of our business. We are seeking a Senior Analyst, reporting to the Director, Global Tax Controversy. The ideal candidate will have subject‑matter experience in tax law and transfer pricing. Experience with contentious tax audits or litigation is a plus, as is experience with foreign tax controversies (including experience with competent authority proceedings like MAPs or APAs), but there will be significant opportunities to gain knowledge and exposure to foreign tax law and procedure over time.

In this role, you will contribute to and organize our responses to federal audits in the U.S., collaborate with colleagues worldwide on foreign audits, and research legal and economic issues related to current and prospective controversies. In addition to your legal skills, you are comfortable compiling and analyzing data and spreadsheets, and you will bring a quantitative skill set to our work.

You should be able to communicate and collaborate effectively with cross‑functional business partners from diverse backgrounds and varying levels of experience. A successful candidate will be highly organized, capable of analyzing complex substantive and procedural tax questions. Given the focus on transfer pricing controversy, the ideal candidate will also understand and be comfortable with the quantitative aspects of transfer pricing methods.

• Research complex tax issues, prepare technical documentation, and assist on special projects.
• Construct transfer pricing models drawing on accounting systems and third‑party data, and dissect and critique tax authority adjustments and models.
• Support the day‑to‑day operations of the company in competent authority proceedings (APAs and MAPs), global income tax audits, resolution procedures, and litigation.
• Review and coordinate responses to Information Document Requests and Requests For Information from taxing authorities.
• Assist in the maintenance of tools to track and quantify audit positions around the world and global tax risk.
• Ensure the complete and timely flow of information in audits and resolution procedures.
• Coordinate with subject matter experts and conduct research on a broad range of US, international, and transfer pricing tax matters.

• Juris Doctor or Master’s (preferred) or Bachelor's degree (major in a field complementary to controversy and transfer pricing matters is a plus).
• 5+ years of relevant experience at a public accounting firm, corporate tax department, or law firm.
• Solid understanding of U.S. and international corporate income tax.
• Experience with transfer pricing, including an understanding of the U.S. and international legal framework, and the economic underpinnings of the methods.
• Proficiency in Excel and the ability to work with and interpret accounting data.
• Familiarity with using frontier AI models to accelerate your research and analysis.
• Ability to juggle multiple projects and produce high‑quality work product in a fast‑paced, dynamic environment.
• Strong oral and written communication skills and the ability to effectively interact cross‑functionally and with external advisors.
• The ideal candidate will work as part of a high‑performance culture built around freedom and…