Senior Tax Manager - International

Airbus•Herndon, VA

1d•$160,000 - $180,000

About The Position

The Senior Tax Manager - International serves as the dedicated “One Roof” subject matter expert and functional lead for US international tax compliance, transfer pricing governance, cross-border structuring, and ASC 740 / IAS 12 international tax accounting across Airbus Americas’ $8B+ annual gross receipts footprint spanning 26+ legal entities and three operating divisions: Commercial Aircraft, Helicopters, and Space & Defense. Reporting directly to the Head of Commercial and Indirect Tax, the role harmonizes cross-border tax policies and establishes a centralized, audit-ready functional center of excellence. The role leads technical tax workstreams for regional mergers, divestitures and acquisitions (MD&A), legal entity rationalization, OECD Pillar Two / GloBE implementation, and defense of international positions during IRS Large Business & International examinations. It provides technical leadership and mentorship to Senior Tax Analysts and serves as the primary business-partnering interface to regional Heads of Finance, Treasury, Legal Counsel, and European Headquarters Group Tax Competence Centers. The position advises European parent entities and US affiliates on international tax matters; leads tax due diligence, transaction structuring, transfer pricing governance and controversy; and directs US international tax compliance and reporting. It also supports global mobility tax topics, departmental digital transformation, and SAP S/4HANA tax integrations. The role requires 10% domestic and international travel and United States citizenship.

Requirements

Bachelor’s degree in accounting from an accredited four-year college or university.
10–12+ years of diverse tax experience, including at least five years in a public accounting tax department or large multinational corporation focused on corporate income tax matters.
In-depth technical knowledge 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.
Proven capability in M&A tax due diligence, Section 338/1060 purchase price allocations, legal entity rationalization, and cross-border restructuring.
English proficiency, including the ability to work with legal documents.
United States citizenship.
Willingness to travel 10% domestically and internationally.

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 within a Big 4 accounting firm, a large multinational corporate tax department, or a combination thereof.
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.
Proficient tax research skills using CCH or equivalent platforms.
Experience with Corptax.
Experience with SAP S/4HANA.

Responsibilities

Provide strategic and technical US and international tax counsel to European parent entities and US affiliates, including advice on inbound capitalization, permanent establishment risks, treaty withholding reductions, corporate distributions, international tax reform, foreign statutory changes, and OECD initiatives.
Partner with divisional Heads of Finance, Procurement, Legal Counsel, and HR on intercompany supply chains, service-level agreements, management fee allocations, intellectual property licensing, and global mobility tax matters.
Provide audit and tax notice support for US and foreign entities on international topics.
Lead MD&A transactions, including due diligence, pre- and post-closing tax inputs, and communications with internal and external stakeholders.
Direct buy-side and sell-side tax due diligence; evaluate target tax exposures; review purchase and financing agreements; and negotiate tax indemnity, representation, and covenant provisions.
Formulate transaction structures, including Section 338(h)(10) / 1060 purchase price allocations, Section 382 attribute preservation, and tax-deferred reorganizations; assess impacts to US consolidated tax positions and develop mitigation strategies.
Drive cross-divisional restructuring and post-closing integration under the One Roof framework, including legal entity rationalization and intercompany financing changes.
Oversee annual transfer pricing documentation and analysis; coordinate with European colleagues on reciprocal effects, adjustments, financial impacts, and cash settlements; monitor results and address policy or compliance gaps.
Oversee operational implementation and renewal negotiations for the bilateral Advance Pricing Agreement between the IRS and French tax authorities.
Lead regional transfer pricing compliance strategies, audits, examinations, and controversy matters; prepare 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 transfer pricing financial models, profitability analyses, reporting tools, and governance processes, and communicate requirements to technical and non-technical stakeholders.
Direct and review annual US international informational 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 Form W-8BEN-E certifications.
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 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 involving international matters.
Mentor Senior Tax Analysts and support business-unit finance leaders, Treasury, Legal Counsel, and European headquarters tax teams.
Design automated workflows using Alteryx and Power BI and support SAP S/4HANA ERP tax integrations related to international topics.
Perform other duties and special projects as assigned, and champion integrity and awareness of compliance risks.