Senior Manager, Special Projects/US Tax

Magna International Inc.•Troy, MI

36d

About The Position

The Senior Manager, Special Projects/ US Tax will support the Tax Department by advising on U.S. Federal and State tax implications arising in the conduct of our business, identifying potential issues, opportunities, and alternatives to deliver timely resolution in an optimal manner.

Requirements

Master's degree in Tax with extensive applicable experience
Certified Public Accountant (CPA)
Fifteen (15) years+ of related experience required with five (5) years in law firm or Big 4 accounting firm.
Ability to travel, including cross-border, 5% - 10%

Nice To Haves

Juris Doctorate with LLM
Strong knowledge of Subchapter C, including M&A, and consolidated return rules; working knowledge of Subchapter K and partnership agreements.
General knowledge of international tax principals, including inbound/outbound taxation and familiarity with US Tax treaties, including mechanics of LOB provisions.
Superior tax research skills to identify, interpret and apply laws, regulations, caselaw, rulings, etc. relevant to addressing a variety of tax issues and opportunities as they arise.
Superior technical writing skills to clearly and concisely present, analyze and document tax positions in memorandums and other written guidance and communications.
Ability to independently identify and evaluate pertinent facts and issues and apply the tax laws in both day-to-day transactions and special projects to determine the consequences, and to provide practical tax advice and application/implementation guidance to personnel both within the Tax Department and in other functional areas of the organization.
Advanced Excel capabilities to develop sophisticated analytical models, including those that require large data sets, to model tax consequences in various M&A, restructuring, and financing scenarios.
Solid understanding of financial accounting concepts and business acumen.
Self-starter and decisive with ability to identify and resolve issues with limited input from senior team members or outside advisors.
Proven ability to effectively juggle/manage multiple projects in time-constrained environment and high-pressure situations.
Ability and willingness to work evenings and weekends as project deadlines dictate.
Strong communication and interpersonal skills to form positive and collaborative working relationships with tax team members and personnel in other functional areas and to clearly and concisely convey complex tax issues and solutions.

Responsibilities

Lead US tax team involvement in external M&A and internal restructurings and planning initiatives in collaboration with non-US counterparts as required, to include due diligence, transaction planning and modeling, making recommendations on tax sections of sale/purchase agreements, and supporting post-closing integration.
Monitor the tax press regularly for actual or potential changes in tax legislation and regulations, or interpretations thereof, and identify, distill, analyze, and disseminate within the Tax group developments with actual or potential significance to the organization.
Present tax planning initiatives to senior leadership.
Research tax implications of return filing positions.
Advise on tax implications of customer and vendor contracts, intercompany arrangements, asset/ stock sale and purchase agreements, partnership agreements, etc. and make recommendations to optimize the organization's position with respect to such implications.
Document issues and technical tax analysis for all projects to include relevant facts, analysis, and citations to applicable authority to defend tax positions on exam.
Lead or assist in dealings with dealings with tax authorities, including prep or review of submissions, and analysis, advocacy and negotiation of position alternatives and settlement agreements.
Maintain the annual Transaction logs and identify, prepare, or review applicable tax return disclosures.
Lead and manage projects and relationships with outside tax and legal advisors.
Special projects and other duties as assigned.