In collaboration with the Senior Director, Transfer Pricing & Tax Controversy, lead EA's U.S. federal tax audits, controversy strategy, manage IRS examinations and assist with negotiation and settlements.
Develop and execute audit defense strategies supported by robust technical documentation and analytics. Ability to advise on the interpretation of IRS Code and Regulations by the IRS Exam Team and Counsel assigned to EA's case.
Prepare strong, technically supported responses to audit queries and documentation requests.
Manage and assist with negotiating Advance Pricing Agreements (APAs) and maintain documentation for U.S. uncertain tax positions (FIN 48).
Provide strategic input on cross-border transactions, IP integration, entity rationalization, and business expansions.
Partner with Legal, Finance, and Treasury to assist in implementing tax-efficient global structures while ensuring compliance.
Represent EA in discussions with tax authorities, demonstrating professionalism, transparency, and strategic negotiation skills.
Advise senior leadership on controversy risk, audit developments, and resolution strategies, including financial statement implications (e.g., FIN 48)
Cross-Functional Leadership
Collaborate effectively across the organization - including Finance, Legal, Accounting, People Experience, and business units - to ensure tax alignment with operational goals.
Communicate complex tax matters clearly to non-tax stakeholders, executives, and the Tax Leadership Team.
Mentor and develop team members globally, fostering a culture of collaboration, inclusion, and technical excellence.
Contribute to EA's broader tax strategy through proactive engagement with policy, industry trends, and technology transformation.
Support process and system improvements leveraging automation and data analytics and participate in strategic initiatives related to EA's ongoing digital and operational transformation.
Requirements
Bachelor's degree in Accounting, Finance, or related field; CPA, JD, or LLM in Taxation strongly preferred.
10+ years of tax consulting, compliance, and reporting experience in Big 4 and/or U.S. multinational corporate tax department, with focus on U.S. and domestic international tax (experience with R&D credit helpful).
Proven success leading IRS tax audits and controversies (controversy experience outside the U.S. also helpful).
In-depth knowledge of U.S. international tax provisions (GILTI/NCTI, FDII/FDDEI, BEAT, FTC) and OECD developments (BEPS, Pillar Two) would be beneficial.
Experience with digital economy taxation, IP structuring, and transfer pricing.
Strong analytical, negotiation, and communication skills with the ability to influence senior leadership and tax authorities.
Experience managing teams and collaborating across global, matrixed organizations.
Self motivated, accountable, and collaborative; able to manage multiple priorities and complex projects simultaneously while working effectively as part of high-performing team.
Additional Information
We're seeking a strategic and experienced leader to drive EA's global tax controversy and transfer pricing strategy. As our US & Global Controversy Lead, you will own the company's U.S. federal audit and controversy efforts (with opportunity to expand to controversy work outside the US), lead Advance Pricing Agreement (APA) strategy and negotiations, and build trusted, long-term relationships with tax authorities.
You will be in a highly visible role requiring deep technical expertise, strong judgment, and the ability to influence outcomes in complex, high-stakes situations relating to U.S. international and domestic taxation and transfer pricing, with proven success managing IRS tax controversies in a fast-paced, digital business environment.
You will bring a proven track record of successfully leading tax audits and disputes, shaping controversy strategy and enabling the team to operate it, and partnering across the business to align tax positions with EA's global operating model. This role reports directly to the Senior Director, Transfer Pricing & Controversy. You will work a hybrid role, requiring three days per week in an EA office
Electronic Arts · Redwood City, CA