JC Ceballos
Transfer Pricing Enthusiast
San Diego
Summary
Unique blend of IRS, Big 4, and in-house leadership experience with proven track record building scalable compliance frameworks and driving alignment between tax strategy and commercial reality across multinational organizations. Fully bilingual in English and Spanish, with extensive experience managing cross-border matters across regions. Passionate about leveraging AI in tax.
Overview
26
26
years of professional experience
Work History
Tax Law Specialist
Internal Revenue Service
San Diego
10.2020 - Current
- Audit Leadership: Led complex IRC §482 audits, partnering with economists, agents, counsel, APMA members and Appeals on high-risk cases, including proposed adjustments exceeding $1B per case.
- Audit Planning & Issue Identification: Reviewed multinational company data to identify transfer pricing risks and selected appropriate issues for audit using advanced data analytics (Excel, AI tools)
- Reviewed multinational data to identify transfer pricing risks and non-arm's-length outcomes, strengthening case positions through interviews with key personnel and consultations with experts.
- Developed and articulated IRS position on transfer pricing matters, preparing written analyses and supporting findings.
Life Sciences Group Transfer Pricing Leader & Global Transfer Pricing Manager
Thermo Fisher Scientific
San Diego
03.2009 - 10.2016
- Led development of cross-border TP policies for intangibles while managing multi-jurisdictional compliance, risk mitigation, and documentation to ensure adherence to OECD and 6662 penalty protection standards.
- Audit Defense, APA & Controversy: Directed TP examinations and competent authority matters across the U.S., Canada, Europe, and Asia. Secured three bilateral APAs with Japan and defended positions in 12+ jurisdictions.
- Streamlined worldwide intercompany transaction processes for $5 billion business unit, reducing quarter-end close from three weeks to one week while overseeing regional service charges, margin analysis, and workflows for enhanced data integrity and reporting accuracy.
- Partnered with 20+ finance, legal, and business stakeholders to align TP strategy with tax efficiency and risk mitigation, fostering collaboration to achieve consensus and meet deadlines.
Transfer Pricing Manager & Senior Analyst
Deloitte (Canada, Mexico) | EY (USA)
06.2000 - 01.2009
- Documentation Leadership - Led preparation of transfer pricing documentation studies for US, Canadian, Mexican, and OECD compliance, specializing in intangible property.
- Global Tax Planning - Contributed to state, federal, and global tax planning initiatives, restructuring supply chains and transfer pricing models to ensure alignment with IRC §482 and OECD guidelines.
- Research & Economic Analysis - Conducted research and analysis of complex transfer pricing issues, leveraging technical expertise to enhance compliance and support planning objectives.
Education
MBA - Finance
Monterrey Institute of Technology and Higher Education
B.S. - Economics
Universidad Autónoma de Guadalajara
Skills
- Tax compliance strategies
- OECD guidelines and BEPS compliance
- BEPS compliance
- Operational transfer pricing
- Data analytics expertise
Languages
Spanish
Professional
Timeline
Tax Law Specialist
Internal Revenue Service
10.2020 - Current
Life Sciences Group Transfer Pricing Leader & Global Transfer Pricing Manager
Thermo Fisher Scientific
03.2009 - 10.2016
Transfer Pricing Manager & Senior Analyst
Deloitte (Canada, Mexico) | EY (USA)
06.2000 - 01.2009
MBA - Finance
Monterrey Institute of Technology and Higher Education
B.S. - Economics
Universidad Autónoma de Guadalajara