Provide US tax and tax legal support for CLIENT Tax department and other functional areas within the organization.
Identify, develop and advise on US federal and state tax considerations of domestic and cross-border tax planning involving restructurings, intercompany financings, and operations/supply chain structuring.
Lead and assume ownership of complex projects, including development and management work program, preparation of quantitative and qualitative analysis to identify options, reach conclusions and make recommendations with appropriate and audit-ready legal and technical support.
Lead buy and sell-side due diligence activities, including data collection/data room management to develop and produce analysis to identify tax risks and opportunities for consideration by transaction team and other decision-makers.
Review, draft, and otherwise advise and make recommendations with respect to US federal and state tax implications of various legal contracts and agreements, including intercompany arrangements, and asset and stock sale and purchase agreements.
Develop and lead presentations, discussions, and explanations of complex tax concepts and issues with senior leadership.
Assist with US corporate tax compliance by maintaining annual transaction log, review of return disclosure forms, and research, development and support of tax return positions.
Manage and collaborate with outside tax and legal advisors.
Assist in preparation of submissions to tax authorities and development/maintenance of FIN 48 support.
Special projects and other duties as assigned.
To perform this job successfully, an individual must be able to perform each essential duty and responsibility satisfactorily. The requirements listed below are representative of the knowledge, skill, ability and/or physical demands required. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.
Education / Certifications
JD; LLM or CPA preferred
Minimum ten (10) years of related experience required with five (5) years in law firm or Big 4 accounting firm.
Strong knowledge of Subchapter C, including M&A, and consolidated return rules; working knowledge of Subchapter K.
Working knowledge of international tax principals, including inbound/outbound, subpart F and FTC regime.
M&A experience, including buy and sell-side diligence, and fluency with tax indemnities and reps & warranties.
Superior technical writing skills to draft clear and succinct tax position memos/opinions, transaction step memos, etc. for distribution to senior decision-makers and to provide practical implementation guidance to relevant functional areas within the organization.
Advanced Excel capabilities to develop sophisticated analytical models to produce and format data to enable users to quickly focus on the key issues/facts/conclusions.
Solid understanding of financial accounting concepts and business acumen.
Excellent organizational skills to compile, manage and store large data sets in a manner that facilitates ready access, analysis, and comprehension.
Self-starter with ability to identify and resolve issues with limited input from senior team members or outside advisors.
Decisive with ability to independently evaluate facts and circumstances to determine and convey conclusions.
Proven ability to effectively juggle/manage multiple projects in time-constrained environment and high pressure situations.
Ability and willingness to work evenings and weekends as project deadlines dictate.
Strong communication and interpersonal skills to form positive and collaborative working relationships with tax team members and personnel in other functional areas.
Carries out responsibilities in accordance with Client’s policies and applicable laws.Responsibilities will include interviewing and training employees; planning, assigning, and directing work; appraising performance; addressing complaints and resolving problems.
While performing the duties of this job, the employee is regularly required to talk, hear and use hands to handle and feel. Vision abilities required by this job include close vision and ability to adjust focus. Office environment, sitting for long periods of time and utilizing computer and telephone excessively. Some travel is required (5-10%), including cross-border.
The statements included in this description are intended to reflect the general nature and level of work assigned to this classification and should not be interpreted as all-inclusive.