Director, US International Tax Planning

📋 Description

• Lead and support US international tax planning projects from initial analysis through
• Analyze the US international tax consequences of business initiatives, including new entities and
• Perform and review technical analysis under subpart F, NCTI, BEAT, and the foreign tax credit
• Apply subchapter C to entity formations, contributions, distributions, liquidations, and internal
• Define the assumptions and scenarios for models that quantify the cash tax and effective tax rate
• Support the M&A tax team after closing by developing the step plans that integrate acquired

🎯 Requirements

• Have deep technical knowledge of the US international tax provisions, including subpart F, NCTI
• Have working knowledge of subchapter C as it applies to multinational groups, including earnings
• Have led tax planning projects end to end, including scoping, technical analysis, modeling
• Understand how planning positions flow into transfer pricing, the ASC 740 provision, and the US
• Can research a technical question in the Code, regulations, and administrative guidance and write a
• Can review a tax model built by someone else, identify where the technical assumptions or mechanics

🎁 Benefits

• Competitive compensation and benefits
• Optional equity donation matching
• Generous vacation and parental leave
• Flexible working hours
• Lovely office space in which to collaborate with colleagues