Tax Senior Manager [Inpatriate/Expatriate]

CohnReznick• , VA

5d•Hybrid

About The Position

CohnReznick is hiring a Tax Senior Manager for its National Tax practice’s International Tax team. The position supports the National International Tax Services practice, focusing on entrepreneurial and high-net-worth individuals with personal, business, investment, and family interests across international borders. Clients include U.S. citizens and residents abroad, foreign individuals moving to or investing in the United States, business owners with foreign interests, international executives, globally mobile families, foreign-fund investors, and individuals considering immigration, residency, or expatriation decisions. The Senior Manager leads technically complex U.S. individual tax compliance and consulting engagements involving international reporting, private-client planning, closely held businesses, foreign investments, trusts and estates, multistate matters, and cross-border transactions. The role combines technical judgment, client leadership, team development, engagement management, and business development. The Senior Manager works closely with Partners while independently managing sophisticated client relationships and contributing to the growth of the National International Tax Services practice. This is a hybrid position. Team members are encouraged to work in person an average of three days per week, with the cadence determined at the team level.

Requirements

Bachelor’s degree in Accounting.
Active CPA license.
Significant progressive tax experience with substantial involvement in complex individual and international individual taxation.
Experience reviewing and taking ownership of complex Forms 1040 and 1040-NR, including responsibility for tax positions and related international reporting.
Experience serving entrepreneurial and high-net-worth individuals, business owners, executives, internationally mobile families, and closely held businesses with foreign investments or transactions.
Strong technical knowledge of U.S. residency, income sourcing, foreign tax credits, and U.S. income-tax treaties.
Strong working knowledge of PFIC, CFC, Subpart F, GILTI, Section 962, FIRPTA, FDAP, and Section 877A expatriation taxation.
Experience reviewing international information reporting, including Forms 5471, 8865, 8858, 8621, 926, 3520/3520-A, 8938, 8833, 8854, and FBARs.
Experience identifying and addressing individual income tax consequences of closely held S corporations, partnerships, and other business interests.
Experience with cross-border trusts and tax and reporting consequences for U.S. and non-U.S. grantors and beneficiaries.
Experience with IRS Streamlined Filing Compliance Procedures and other international tax-compliance remediation matters.
Ability to analyze sophisticated Forms K-1 and K-3, foreign financial statements and tax returns, brokerage statements, investment-fund reporting, and other complex financial information.
Strong tax research and technical-writing skills, including the ability to develop and defend technically supportable positions.
Ability to independently resolve complex, fact-intensive tax issues and recognize matters requiring Partner or specialist involvement.
Ability to perform effectively under tight deadlines and significant pressure while maintaining technical accuracy, sound judgment, and high client-service standards.
Ability to lead multiple complex engagements and prioritize rapidly changing deadlines and client demands.
Experience managing engagement economics, including budgets, staffing, billing, and collections.
Business development experience, including originating opportunities, expanding client relationships, participating in proposals and prospect meetings, and developing referral relationships.
Ability to develop and maintain trusted relationships with sophisticated clients and their attorneys, investment advisers, family offices, wealth managers, and foreign tax advisers.
Ability to lead, mentor, and develop tax professionals at multiple levels.
Strong written and verbal communication skills, including the ability to clearly explain technical international tax issues to clients and other advisers.

Responsibilities

Lead and review complex Forms 1040 and 1040-NR for U.S. citizens, resident aliens, nonresident aliens, dual-status taxpayers, and internationally mobile individuals.
Advise entrepreneurs, high-net-worth individuals, business owners, executives, and globally mobile families on complex U.S. and international individual tax matters.
Advise on U.S. tax residency, including green card and substantial presence tests, closer-connection and treaty tie-breaker positions, dual-status taxation, and residency start and termination dates.
Lead foreign tax credit analyses, including income sourcing, treaty resourcing, foreign tax redeterminations, credit carryovers, and expense allocation and apportionment.
Review and advise on international reporting requirements, including Forms 5471, 8865, 8858, 8621, 926, 3520/3520-A, 8938, 8833, 8854, FinCEN Form 114, and related filings.
Advise on foreign corporation matters, including CFC status, constructive ownership, Subpart F, GILTI, Section 962 elections, previously taxed earnings and profits, distributions, and shareholder-level consequences.
Lead analysis of foreign investment portfolios and PFIC reporting, including QEF and mark-to-market elections, Section 1291 calculations, inclusions, distributions, and dispositions.
Review foreign partnership and private-investment-fund reporting, including entity classification, Forms K-1 and K-3, underlying PFIC investments, foreign-source income, and partner-level reporting obligations.
Advise on interactions between individual income tax returns and interests in U.S. and foreign partnerships, S corporations, C corporations, foreign corporations, trusts, and disregarded entities.
Identify and address basis, at-risk, passive activity, NIIT, excess business loss, Section 163(j), and related limitations in complex individual tax engagements.
Lead tax matters involving foreign trusts and estates and internationally connected grantors and beneficiaries.
Advise on foreign pension, retirement, and deferred-compensation arrangements and their U.S. tax, treaty, and reporting implications.
Advise on pre-immigration and expatriation planning, including long-term residency, Form 8854, Section 877A, and related considerations.
Review foreign financial statements, tax returns, brokerage statements, investment-fund reporting, and other foreign-source documentation for U.S. tax treatment.
Provide technical oversight of amended returns, delinquent international filings, IRS Streamlined Filing Compliance Procedures, and other international compliance remediation matters.
Lead tax projections, estimated-tax calculations, extensions, and cash-tax planning for clients with income and investments across multiple entities and jurisdictions.
Coordinate with attorneys, investment advisers, family offices, foreign tax advisers, and other professionals to deliver integrated client solutions.
Manage complex engagements under compressed deadlines while maintaining technical accuracy, client responsiveness, and review standards.
Manage engagement economics, including scoping, budgeting, staffing, realization, billing, and collections.
Direct and review the work of Senior Associates, Associates, and offshore professionals, providing clear and actionable technical review comments.
Develop junior professionals through coaching, technical training, delegation, and Career Advisor responsibilities.
Generate new client opportunities and expand existing relationships through business development activities.
Identify additional international tax, private-client, and related advisory opportunities arising from clients’ business, investment, and family activities.
Participate in prospect meetings, proposal development, pricing discussions, engagement scoping, and new-client onboarding.
Build referral relationships with attorneys, wealth managers, family offices, financial advisers, foreign accounting firms, and other professional-service providers.
Work with Partners on market strategies targeting entrepreneurial and high-net-worth international individuals.
Represent the firm through conferences, professional organizations, client events, webinars, presentations, articles, and other thought leadership.
Develop a professional network and market presence that contributes to growth of the National International Tax Services practice.