Senior Manager, International Tax
About The Position
The Senior Manager, U.S. International Tax will serve as a key member of the global tax team and provide technical leadership in all aspects of U.S. international tax compliance, provision, planning, and business support. This role will partner closely with Finance, Accounting, Treasury, Legal, FP&A, and external advisors to manage the company's global tax obligations, support strategic initiatives, and optimize the worldwide tax profile. The ideal candidate will possess strong technical expertise in U.S. international taxation, ASC 740, foreign tax credits, global restructurings, and cross-border transactions, along with the ability to operate effectively in a fast-paced, multinational environment.
Requirements
- Bachelor's degree in Accounting, Finance, Tax, or related field.
- CPA, Master's in Taxation.
- 10+ years of progressive tax experience with significant U.S. international tax exposure.
- Combination of Big Four and multinational corporate tax experience preferred.
- OECD Pillar Two Experience supporting public company tax reporting requirements.
- Strong project management, analytical, and communication skills.
- Ability to manage multiple projects and deadlines in a dynamic environment.
- Strong technical knowledge of: Foreign Tax Credits (FTC), Foreign branch rules, FDII, ASC 740, Cross-border restructurings, M&A tax considerations, Section 382.
Responsibilities
- Responsible for the technical execution and support of the ASC740 quarterly tax provision process, particularly for international tax matters.
- Prepare and review GILTI, FDDEI, FTC, and foreign branch calculations.
- Analyze international deferred tax assets and liabilities.
- Prepare ASC 740 technical memoranda.
- Analyze uncertain tax positions.
- Support quarterly and annual provision processes including SOX controls and documentation.
- Coordinate with external advisors on technical tax accounting matters.
- Respond to external auditor information requests.
- Support/lead execution and technical review of U.S. international tax compliance (Forms 5471, 8858, 8865, 1118, etc.).
- Coordinate annual compliance with external advisors for all nonUS filings.
- Gather and validate foreign entity financial data.
- Review E&P, tax pools, FTC calculations, and foreign disclosures.
- Monitor compliance impacts of restructurings and transactions.
- Improve compliance processes and documentation.
- Support tax audits and information requests.
- Serve as the technical execution lead for M&A activities.
- Perform tax due diligence reviews.
- Analyze tax attributes and utilization of NOLs, FTCs, credits, E&P.
- Review Section 382 implications.
- Evaluate international tax consequences of acquisitions and dispositions.
- Build transaction and integration models.
- Coordinate with external advisors on M&A.
- Identify tax risks and opportunities related to M&A.
- Support purchase accounting and ASC 740 impacts for M&A.
- Support tax planning by modeling tax implications from different scenarios.
- Analyze FTC utilization, general basket vs. foreign branch basket implications.
- Quantify cash tax savings, ETR implications, and other tax consequences.
- Prepare technical memos and coordinate with external advisors on technical analyses for tax planning.
Benefits
- variable compensation
- Bonus/equity may be available
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What This Job Offers
Job Type
Full-time
Career Level
Senior
