Senior International Tax Manager
The candidate will assist with supporting US international inbound and outbound tax planning and supporting company's various business offerings. Will team up with other international tax team members, collectively operating as business partners, gaining a deep, end-to-end understanding of various business initiatives. Assist with communicating current and future business plans, obtaining cross functional tax subject matter input to address all tax disciplines, and ensure coordination of cross functional tax solutions. Gain a deep understanding of business initiatives, models, goals, and drivers, including gaining a deep understanding of the technologies and/or intellectual property used to launch business initiatives. Identify and document business proposals. Design and lead the implementation of optimal tax structures for various new business initiatives (e.g. income sourcing, income characterization, PE analysis, funding, currency issues, etc.). Develop strategies to minimize the potential Subpart F generated by proposed business models. Assist with the evaluation of proposed business models with an aim at developing strategies to mobilize foreign cash, maximize tax effective foreign cash repatriation, and generally coordinate and liaise with the treasury department with respect to global cash management. Liaise with financial personnel as well as both US and foreign outside tax advisors. Write technical and non-technical tax research and compliance memos. Write detailed tax requirements to be used by various business partners throughout the company. Develop and maintain knowledge of federal and international tax laws and current developments. Monitor industry positions relevant to company's international business operations. May be responsible for planning, coordinating, supervising and reviewing the work of more junior tax staff.
The candidate should have J.D. or Bachelor's degree in accounting preferably with CPA, MST or LL.M. degree. Must have 8+ years of progressive international tax income tax experience in a large corporate environment and/or public accounting or large law firm. Understanding of accounting concepts is required. Must have a strong managerial background with superb project management experience, and a good understanding of the international tax provisions of the Internal Revenue Code and Regulations.
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