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Manager, Production Tax Counsel
Refer job# JSCH147770
 
Manager, Production Tax Counsel The candidate will be responsible for supporting the Production Tax Counsel and the Studio and Media segments in day-to-day operations regarding the production of motion pictures and TV programs in the US and abroad. This position plays a key role in providing tax advice to the business units involved in content production activities for purposes of tax incentive qualification and mitigation of tax risks consistent with the brand and risk profile. Plan and implement legal arrangements, legal entity relationships and day-to-day tax support for the Studio and Media segments in the production of motion pictures and episodic programs. Provide guidance to the segments and Tax: structure of legal entity transactions and production activities by legal entities to proactively plan for relevant production incentives and applicable thresholds for permanent establishment status, cross border workforce issues (WHT, VAT and other tax considerations including relevant treaty analysis and union/guild rules), and tax considerations for contingent compensation and loan out companies. Legal research, analysis and memo writing on technical tax matters (e.g., bonus depreciation, income forecast method, compensation arrangements, taxable versus nontaxable legal entity liquidations, consolidated returns, and tax accounting methods). Provide support to the Production Tax Counsel on material transactions, tax compliance methodologies and in proactive planning (U.S., state and local and INTL with local tax desks). Preparation of legal agreements for intercompany activities where necessary to qualify for production incentives or to mitigate tax risks.

The candidate should have a BA/BS Economics, Accounting, Business, Finance or other similar fields preferred. Law Degree and admission to a state bar (with membership in good standing). 6 10 years of work experience in an accounting or tax department at a corporation or equivalent experience at a Big 4 accounting firm or similar. Film or TV production budgeting and accounting. Quantitative modeling and powerpoint experience. Substantive US federal income tax experience (research, writing and compliance). Income tax accounting familiarity and awareness on material considerations including outside of uncertain tax positions. Project management experience. Public accounting tax experience involving the entertainment industry preferred. Master in Tax and/or Accounting preferred.
 
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