Senior Tax Manager - International

Airbus•Herndon, VA

1d•Remote

About The Position

The Senior Tax Manager - International serves as the dedicated subject matter expert and functional lead for US international tax compliance, transfer pricing governance, cross-border structuring, and international tax accounting under ASC 740 and IAS 12 across Airbus Americas’ footprint of more than $8 billion in annual gross receipts, 26+ legal entities, and three operating divisions: Commercial Aircraft, Helicopters, and Space & Defense. Reporting directly to the Head of Commercial and Indirect Tax, this role harmonizes cross-border tax policies and establishes a centralized, audit-ready center of excellence. The position leads technical tax workstreams for regional mergers, divestitures and acquisitions, legal entity rationalization, OECD Pillar Two/GloBE implementation, and defense of international tax positions during IRS Large Business & International examinations. It provides technical leadership and mentorship to Senior Tax Analysts and partners with regional business unit Heads of Finance, Treasury, Legal Counsel, and European Headquarters Group Tax Competence Centers on intercompany supply chains, service level agreements, and cross-border financing. The role also advises European parent entities and US affiliates on international tax matters; leads tax due diligence, transaction structuring, and post-closing integration; oversees transfer pricing documentation, compliance, and controversy; and directs US international information-return compliance, withholding, tax provision, and audit matters. Additional duties include supporting digital transformation through automated workflows and SAP S/4HANA tax integrations. Travel required: 10% domestic and international.

Requirements

Bachelor’s degree in accounting from an accredited four-year college or university.
10–12+ years of diverse tax experience, including at least 5 years in a public accounting tax department or large multinational corporation focused on corporate income tax matters.
In-depth technical mastery of US inbound and outbound corporate taxation, including Sections 163(j), 267A, 385, 482, 59A (BEAT), and 250 (FDII), Subpart F, and foreign tax credits.
Comprehensive understanding of OECD Transfer Pricing Guidelines, BEPS Action items, and readiness frameworks for Pillar Two GloBE rules.
Ability to manage projects independently from inception to completion in a fast-paced, multi-entity environment.
Experience with M&A tax due diligence, Section 338/1060 purchase price allocations, legal entity rationalization, and cross-border restructuring.
Proficient tax research skills using CCH or equivalent platforms.
English proficiency, including the ability to work with legal documents.
Current work authorization for the United States; the company states it does not sponsor visas for US positions unless specified.

Nice To Haves

Master of Laws (LL.M.) in Taxation, Juris Doctor (J.D.), or Master of Science in Taxation (MST).
Four to five years dedicated to US international tax compliance, transfer pricing, or cross-border structuring in a Big 4 accounting firm, large multinational corporate tax department, or a combination of both.
Experience with inbound companies.
Experience in the aerospace industry or manufacturing.
Certified Public Accountant (CPA) licensure, J.D., and/or LL.M.
Exposure to consolidated return regulations, combined/consolidated/unitary state filing requirements, ASC 740 footnote disclosures, FIN 48 accounting for uncertain tax positions, Subchapter C, corporate distributions and adjustments, and informational reporting for inbound corporations.
Experience with Corptax.
Experience with SAP S/4HANA.

Responsibilities

Provide strategic and technical tax advice to European parent entities and US affiliates on inbound capitalization, permanent establishment risks, treaty withholding reductions, corporate distributions, US international tax reform, foreign statutory changes, and OECD initiatives.
Partner with divisional Heads of Finance, Procurement, Legal Counsel, HR, and other business teams on intercompany supply chains, service level agreements, management fee allocations, intellectual property licensing, global mobility, and cross-border financing.
Provide audit and tax-notice support for US and foreign entities on international tax matters.
Lead buy-side and sell-side tax due diligence for mergers, divestitures, and acquisitions; assess target tax exposures, review agreements, and negotiate tax indemnities, representations, and covenants.
Develop transaction structures, including purchase price allocations, attribute preservation, and tax-deferred reorganizations, to support tax basis step-ups, amortizable goodwill, and post-transaction tax attribute use.
Assess impacts of transactions on US consolidated tax positions, including BEAT and GILTI, and develop mitigation strategies as needed.
Drive cross-divisional restructuring and post-closing integration under the One Roof governance framework, including legal entity rationalization and intercompany financing improvements.
Oversee annual transfer pricing documentation and analysis; collaborate with European colleagues on reciprocal effects, adjustments, financial impacts, and settlements.
Monitor transfer pricing results, identify policy and compliance gaps, recommend adjustments, and support implementation of transfer pricing models.
Coordinate internal data collection and external tax-firm analyses and deliverables; oversee operational implementation and renewal negotiations for a bilateral Advance Pricing Agreement with the IRS and French tax authorities.
Design, implement, and maintain regional transfer pricing compliance and strategies aligned with business goals and regulatory requirements.
Lead transfer pricing audits, examinations, and controversy matters, preparing analyses, documentation, and responses to tax authority requests.
Partner with Finance, Supply Chain, and business teams on tax-efficient operating models, restructurings, acquisitions, and other strategic initiatives; develop financial models, profitability analyses, reporting tools, and governance processes.
Direct and review annual US international information returns and disclosure packages, including Forms 5471, 5472, 8858, and 8865; prepare and review certain Forms 1120-F.
Oversee foreign withholding compliance, including annual Forms 1042/1042-S and review of Forms W-8BEN-E for US operating affiliates.
Manage BEPS reporting and data collection for US entities, including Country-by-Country Reporting and OECD Pillar Two/GloBE data packs for the European group tax team.
Monitor Section 385 documentation, Section 163(j) intercompany interest limitations, and outbound dividend and debt flows in coordination with Treasury and corporate financing teams.
Compute and review international aspects of quarterly and annual income tax provisions under ASC 740 and IAS 12 for US consolidated entities and standalone inbound reporting entities.
Calculate and review foreign tax credits, Subpart F, GILTI, BEAT, FDII, and foreign withholding tax accruals; assess uncertain tax positions under FIN 48 (ASC 740-10).
Lead IRS or state tax audits, examinations, and controversy on international matters, preparing analyses, documentation, and responses to tax authority requests.
Champion department digital transformation by designing automated workflows using Alteryx and Power BI and supporting SAP S/4HANA ERP tax integrations related to international topics.
Perform other duties as assigned and support special projects.