Cross Border Tax Private Wealth, Senior Manager (Bilingual FR/EN)

Pwc Canada•Montreal, QC

3d•CA$128,900 - CA$178,900

About The Position

A career within PwC Private's High Net Worth (HNW) practice offers the opportunity to advise some of Canada's most iconic families and individuals on the full spectrum of Canada–U.S. cross-border tax matters. Our HNW Cross Border team helps clients navigate U.S. and Canadian tax considerations across personal, trust, and corporate structures, designing and implementing tailored, multi-jurisdictional strategies that reflect the unique circumstances of HNW individuals, U.S. citizens residing in Canada, Canadians with U.S. assets or family ties, and intergenerational families with members on both sides of the border. You'll work alongside a dedicated team of cross-border specialists on engagements that span cross-border income and estate tax planning, U.S./Canadian trust structuring, CFC and PFIC analysis, foreign information reporting, and pre-immigration and pre-departure planning, helping families preserve, grow, and transition wealth across generations and jurisdictions. As a Cross Border Tax Senior Manager, you'll work as part of a team of problem solvers, helping to solve complex business issues from strategy to execution. PwC Professional skills and responsibilities for this management level include but are not limited to: - Technical / role-specific: Navigate the complexities of cross-border tax engagements involving multidisciplinary teams to deliver integrated solutions. Advise HNW individuals and families on Canada–U.S. cross-border income, estate, and gift tax planning, including planning for U.S. citizens resident in Canada, Canadians with U.S. assets or U.S.-resident beneficiaries, and pre-immigration and pre-departure scenarios. Assist on cross-border structuring engagements, including the design and implementation of entity structures, including trusts, spanning Canada and the U.S., with attention to treaty application, entity classification, and downstream reporting impact. Conduct technical analysis of foreign trusts, including classification, throwback exposure, DNI/UNI tracking, and the related U.S. reporting obligations. Perform and review CFC and PFIC analyses and planning, including Subpart F, NCTI, and QEF modelling, and the supporting quantitative computations. Assist on estate and intergenerational wealth transfer planning for cross-border families, including will and trust reviews, U.S. estate and gift tax exposure, and the integration of Canadian and U.S. rules, including life insurance considerations. Build and review quantitative models and projections (e.g., basis tracking, foreign tax credits, departure tax, U.S. estate exposure, throwback) to quantify exposures and support client recommendations. Review Canadian and U.S. personal and trust tax returns, as well as foreign information returns (e.g., Forms 3520, 3520-A, 5471, 8621, 8865, 8858, FBAR/FinCEN 114; T1135, T1141, T1142), to ensure that planning recommendations are correctly implemented and reported. Identify and communicate cross-border tax risks to engagement teams and clients through technical memos, red-flag reports, and client-ready summaries. Stay current on Canadian and U.S. tax legislation, treaty developments, IRS and CRA guidance, and emerging cross-border planning trends, and develop subject matter expertise in your area of specialization. - PwC Professional / leadership: Initiate open and candid coaching conversations at all levels. Move easily between big picture thinking and managing relevant detail. Contribute to an environment where people and technology thrive together to accomplish more than they could apart. Encourage everyone to have a voice and invite opinions from all, including quieter members of the team. Initiate and lead open conversations with teams, clients and stakeholders to build trust. Uphold the firm's code of ethics and business conduct.

Requirements

Experience in public accounting, handling complex Canada-U.S. cross-border tax planning and compliance for high-net-worth clients, with knowledge of Canadian and U.S. tax rules and legislation.
Practical experience with CFC and PFIC calculations, as well as foreign trust reporting and estate tax filings.
Between 3-4 years of experience in a manager level or a similar role within an accounting firm, delivering tax consulting and compliance services, as well as cross-border estate tax planning experience.
Canadian CPA designation or US CPA Enrolled Agent (EA) designation, all in good standing (required).
Superior problem-solving skills, excellent verbal, written, and presentation skills.
Strong analytical capability, sound business sense and creative mind that have earned you a reputation for providing excellence in client service.
Proven ability to manage multiple assignments, clients, and staff, ensuring efficient and effective project delivery.
Demonstrated business development skills and enthusiasm for contributing to the growth of the high-net-worth practice.
Ability to manage, develop, retain, and mentor junior tax professionals, fostering a collaborative and growth-oriented team environment.
Strong research, organizational skills, the ability to work effectively under pressure, and a proactive attitude.
Fluency in English, in addition to French as they will be required to support or collaborate with English-speaking clients, colleagues and/or stakeholders during their employment with PwC Canada.

Responsibilities

Navigate the complexities of cross-border tax engagements involving multidisciplinary teams to deliver integrated solutions.
Advise HNW individuals and families on Canada–U.S. cross-border income, estate, and gift tax planning, including planning for U.S. citizens resident in Canada, Canadians with U.S. assets or U.S.-resident beneficiaries, and pre-immigration and pre-departure scenarios.
Assist on cross-border structuring engagements, including the design and implementation of entity structures, including trusts, spanning Canada and the U.S., with attention to treaty application, entity classification, and downstream reporting impact.
Conduct technical analysis of foreign trusts, including classification, throwback exposure, DNI/UNI tracking, and the related U.S. reporting obligations.
Perform and review CFC and PFIC analyses and planning, including Subpart F, NCTI, and QEF modelling, and the supporting quantitative computations.
Assist on estate and intergenerational wealth transfer planning for cross-border families, including will and trust reviews, U.S. estate and gift tax exposure, and the integration of Canadian and U.S. rules, including life insurance considerations.
Build and review quantitative models and projections (e.g., basis tracking, foreign tax credits, departure tax, U.S. estate exposure, throwback) to quantify exposures and support client recommendations.
Review Canadian and U.S. personal and trust tax returns, as well as foreign information returns (e.g., Forms 3520, 3520-A, 5471, 8621, 8865, 8858, FBAR/FinCEN 114; T1135, T1141, T1142), to ensure that planning recommendations are correctly implemented and reported.
Identify and communicate cross-border tax risks to engagement teams and clients through technical memos, red-flag reports, and client-ready summaries.
Stay current on Canadian and U.S. tax legislation, treaty developments, IRS and CRA guidance, and emerging cross-border planning trends, and develop subject matter expertise in your area of specialization.
Initiate open and candid coaching conversations at all levels.
Move easily between big picture thinking and managing relevant detail.
Contribute to an environment where people and technology thrive together to accomplish more than they could apart.
Encourage everyone to have a voice and invite opinions from all, including quieter members of the team.
Initiate and lead open conversations with teams, clients and stakeholders to build trust.
Uphold the firm's code of ethics and business conduct.