Manager, Global Transaction Tax (International)

Qualifications

• CPA, JD (with bachelor's degree in accounting, preferred), or LLM required
• At least 3 years of relevant experience in a mergers & acquisitions tax practice at a Big 4 firm, Big Law firm, or similar firm, and at least 2+ years of experience in US international tax
• Strong writing, analytical, research, excel, and organizational skills
• Strong communication, presentation, project management, and business development skills
• Strong sense of personal motivation as well as the ability to work with a team
• Ability to work in a dynamic, time-sensitive environment

Responsibilities

• Perform due diligence including review of US tax returns, financial statements, and other tax documentation to evaluate potential US international tax risks and opportunities, and summarize identified risks and opportunities in a commercial manner.
• Aid in reviewing and commenting on US international tax aspects of financial models and purchase agreements.
• Collaborate with federal, transfer pricing, non-US tax teams and other specialists to deliver the highest quality work product.
• Demonstrate an understanding of key US international tax consequences for various deal structures, including, but not limited to, financing, repatriation, treaty, CFC and PFIC considerations.
• Demonstrate an ability to research and analyze complex US international tax issues.
• Aid in the design and implementation of comprehensive global tax restructurings and planning opportunities.
• Stay abreast of developments in US international tax.
• Build relationships with clients and across Tax and the rest of A&M.