Manager, M&A Tax and Controversies

Salesforce•San Francisco, CA

8d•$123,100 - $202,600•Hybrid

About The Position

Salesforce is looking for an experienced Tax Manager to join their Tax team, focused on M&A tax and tax controversy matters. This role will work closely with cross-functional teams including Finance and Legal to support M&A and IRS audit defense. The role requires working from the San Francisco office 3 days a week.

Requirements

5-7+ years of tax experience, preferably in a Big 4 accounting firm and/or in an in-house tax department of a large multinational corporation
CPA preferred
Experience in technology or software industry with a strong understanding of accounting for income taxes under US GAAP (ASC 740).
Familiarity with FIN 48 / ASC 740 analysis
Experience providing tax support (particularly computational analysis/modeling) for tax planning, M&A, investments, including due diligence, structuring, and integration.
Knowledge of international tax principles, including transfer pricing
Experience with US federal income tax controversy, including IRS examinations, the administrative appeals process, and litigation.
Excellent written and verbal communication skills; ability to work cross-functionally

Nice To Haves

Experience with Oracle, NetSuite, or other enterprise platforms is a plus

Responsibilities

Support M&A due diligence and deal structuring including preparation of computational analysis related to key US domestic and international tax provisions, including GILTI, subpart F, foreign tax credits, FDII, BEAT, and section 163(j) for M&A activities (new acquisitions, acquired entity integrations, and corporate restructurings)
Manage M&A tax integration activities, coordinating and implementing tax restructuring plans to include, among others, integration of employees and intangible property; contract migration; intercompany billing arrangements, etc.
Manage income tax compliance for acquired entities, including the preparation and filing of US federal income tax returns (short-period and annual filings); section 382 analyses; transaction cost analysis; etc.
Monitor local country tax compliance and reporting obligations for foreign acquired entities related to company M&A activities in coordination with external advisors and local country Finance and Tax teams.
Document tax exposures, tax / legal positions, and planning strategies for business initiatives, M&A transactions, and operational structures.
Collaborate with cross-functional teams to gather and prepare documentation as part of tax planning and controversy matters
Draft substantive responses to IRS Information Document Requests (IDRs) and inquiries from tax authorities.