Senior Manager | International Tax

Requisition Number2232813 Description & Requirements

Forvis Mazars is seeking an International Tax Senior Manager within a fast-growing public accounting firm serving a broad range of clients from middle-market companies to publicly traded corporations.

How you will contribute :

Managing restructuring and M&A transactional projects from a U.S. federal income tax perspective. Such projects could include purely domestic transactions as well as transactions involving foreign entities.

Thus, the candidate should have a solid understanding of the corporate non-recognition tax rules, the U.S. consolidated return tax rules, the partnership tax rules, and the U.

S. international tax rules.

• Typical projects managed could include the following (domestic and / or foreign) :
• Corporate restructuring of legal entities in a tax-deferred manner (e.g., IRC section 351, 332, 368, 355, 367, etc.)
• Legal Entity Rationalizations ("LERs")
• E&P studies (including U.S. consolidated tax group and foreign entities).
• Tax basis studies (i.e., tax basis of stock including U.S. consolidated tax groups or tax basis of assets)
• Worthless stock deductions (including in a U.S. consolidated group)
• Transactions involving partnerships
• Buy / sell
• Restructurings
• Debt financed distributions
• Cash repatriation and dividend planning
• Transactions involving members of a U.S. consolidated tax group
• Out from under planning
• Debt modification / refinancing including unwinding intercompany loans
• Debt vs. equity analysis
• Third-party buy / sell structuring
• Stock vs. assets sale / buy
• Modeling
• 338(g) / 336(e) / 338(h)(10) elections
• Installment sale planning
• Restructures prior to the sale
• Post-purchase restructuring
• Planning and modeling regarding U.S. international tax rules (GILTI, subpart F, foreign tax credits, BEAT, FDII, IRC sec. 163(j), etc.)
• Treaty analysis
• When not involved in transaction projects, the candidate would be expected to advise on and manage international tax projects (GILTI, Subpart F, foreign tax credits, BEAT, FDII, etc.)
• Responsibilities with respect to the above would include :
• Growing and developing team members,
• Business development,
• Heavy client communications,
• Working with attorneys to execute transactions and reviewing legal documents,
• Issuing slide decks detailing the steps of the transaction(s),
• Working with foreign affiliates for non-U.S. tax consequences,
• Issuing technical memorandums and / or tax opinions,
• Excel modelling of transaction(s),
• Billing and collecting

Minimum Qualifications :

• Juris Doctor (preferably with an LL.M. in Taxation) and / or CPA
• 8 years or more of transactional / consulting experience in a law firm or CPA firm
• Strong analytical, research, computational, writing, and planning skills

LI-BOCR, #LI-OAK, #LI-IND, #LI-CLTSP, #LI-TYS

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With a legacy spanning more than 100 years, Forvis Mazars is committed to providing a different perspective and an unmatched client experience that feels right, personal and natural.

We respect and reflect the range of perspectives, knowledge and local understanding of our people and clients. We take the time to listen to deliver consistent audit and assurance, tax, advisory and consulting services worldwide.

We nurture a deep understanding of our clients’ industries, delivering greater insight, deeper specialization and tailored solutions through people who listen to understand, are responsive and consult with purpose to deliver value.

About Forvis Mazars, LLP

Forvis Mazars, LLP is an independent member of Forvis Mazars Global, a leading global professional services network. Ranked among the largest public accounting firms in the United States, the firm’s 7,000 dedicated team members provide an Unmatched Client Experience through the delivery of assurance, tax, and consulting services for clients in all 50 states and internationally through the global network.

Visit forvismazars.us to learn more.

Forvis Mazars, LLP is an equal opportunity / affirmative action employer. Employment selection and related decisions are made without regard to age, race, color, sex, sexual orientation, national origin, religion, genetic information, disability, protected veteran status, gender identity, or other protected classifications.

It is Forvis Mazars, LLP standard policy not to accept unsolicited referrals or resumes from any source other than directly from candidates.

Forvis Mazars, LLP expressly reserves the right not to consider unsolicited referrals and / or resumes from vendors including and without limitation, search firms, staffing agencies, fee-based referral services, and recruiting agencies.

Forvis Mazars, LLP further reserves the right not to pay a fee to a recruiter or agency unless such recruiter or agency has a signed vendor agreement with Forvis Mazars, LLP.

Any resume or CV submitted to any employee of Forvis Mazars, LLP without having a Forvis Mazars, LLP vendor agreement in place will be considered the property of Forvis Mazars, LLP.