Strategic Tax Planning Manager
The candidate will report to a Director of Strategic Tax Planning. Will focus primarily in the area of tax planning. Assist in development and implementation of strategic initiatives to reduce global taxes in a time of changing tax legislation in the US and abroad. Assist with international and federal tax aspects of acquisitions and divestitures, including complex cross-border reorganizations transactions, including development of tax efficient acquisition and divestiture structures. Coordinate and implement the US tax implications of global tax planning with the Company's European and Asian Regional Tax Managers. Assist in optimizing overseas cash balances. Lead efforts to simplify the global legal entity structure in a tax efficient manner. Develop foreign tax credit and foreign source income optimization structures and strategies. Good understanding of Subchapter C of the Internal Revenue Code and Treasury Regulations thereunder. Assist in review of the international components of US federal income tax return including Forms 5471, 8858, 8865 and 1118. Monitor and manage tax attributes like E&P, Tax Pools, Section 987 gains and losses, 905(c), FTC, Tax Basis, Subpart F and Section 956 inclusions. Assist with the international tax IRS audits. This includes working with the international field auditors on the IDR responses, positioning to minimize any exposure, negotiations and protests. Review and continued monitoring of planning transactions during and post implementation in accordance with US and non-US requirements. Establish a thorough understanding reporting systems and procedures in the tax department while working to continually refine and improve procedures to gain operating efficiencies. Monitor and report on foreign tax trends and developments as they impact the organization on an on-going basis.
The candidate should have a Bachelor's degree in finance or accounting. CPA, MST, or J.D. degree is preferred. Must have 4-8 years of international tax and provision experience in Big 4 or comparable tax experience in a large multinational corporation. Computer proficiency with HFM and Corp Tax a plus. Should have a good understanding of transactional concepts relating to mergers and acquisitions and divestitures, Subchapter C, Reorganizations, as well as transfer pricing matters.
|
