Director, Tax Controversy

About the role

Electronic Arts is seeking a strategic leader to head its global tax controversy and transfer pricing efforts. As Director, Tax Controversy you will own U.S. federal audit and controversy work, with potential to expand internationally, and lead Advance Pricing Agreement negotiations.

Key responsibilities

• Lead EA’s U.S. federal tax audits and controversy strategy, managing IRS examinations and settlement negotiations.
• Develop and execute audit defense strategies supported by technical documentation and analytics.
• Advise on IRS Code and regulation interpretation and prepare technically robust responses to audit inquiries.
• Negotiate and maintain Advance Pricing Agreements (APAs) and documentation for uncertain tax positions (FIN 48).
• Provide strategic input on cross‑border transactions, IP integration, entity rationalisation and business expansions.
• Partner with Legal, Finance, Treasury and other functions to design tax‑efficient global structures while ensuring compliance.
• Represent EA in discussions with tax authorities, communicating risk and resolution strategies to senior leadership.

Required profile

• Proven track record of leading tax audits and disputes in a fast‑paced digital business environment.
• Deep technical expertise in U.S. international and domestic taxation and transfer pricing.
• Strong judgment and ability to influence outcomes in high‑stakes situations.
• Experience managing IRS controversies and negotiating settlements.
• Ability to collaborate across Finance, Legal, Accounting and business units.

Required skills

• IRS Code and regulation interpretation.
• Audit defense strategy development.
• Advance Pricing Agreement (APA) negotiation.
• FIN 48 documentation and uncertain tax position reporting.
• Transfer pricing analysis.