Manager/Sr Manager of Tax Advisory

Manager and senior manager of tax advisory – manager 145-170k, senior manager/associate director – 190-235k – Global Investment Bank

THE ROLE – Sr. Manager (associate director), Tax Advisory – Americas

This role will be part of the Tax Advisory group in NY which offers diverse exposure to US federal and international tax issues working on new transactions and businesses across the Investment Group

  • Work closely with business units and other members of the Tax team globally
  • Work closely with the executives from the Business Units at both junior and senior levels
  • Work closely with Business Unit finance teams
  • Work closely with the Tax  Reporting and Finance teams

CLIENT CONTACT/ RELATIONSHIPS

  • Brief external tax advisors in order to obtain written advice and opinions
  • Part of a NY-based team that covers the Americas, ex-Canada
  • Regular exposure to other members of Group Tax globally.

KEY RESPONSIBILITIES

  • Providing federal tax support in relation to transactions by or within the  Group involving the Americas Region.  This will include the following:
  • Supporting and working with senior members of the Tax Advisory Group on both business unit issues and transactions and central tax issues
  • Covering specific business units as Tax Advisory’s representative
  • Researching a broad range of substantive tax issues, including consolidated return rules, international tax (with a focus on inbound), subchapter C and addressing questions from the business and the Tax Reporting Team relating to substantive tax issues
  • Preparation of internal memoranda regarding tax analysis and tax positions
  •     Liaise with the business areas and Tax Reporting and Finance teams in relation to various transactions and central tax issues that arise on a day-to-day basis
  • Working with external advisors on transactions and obtaining local (non-US) tax advice related to the Americas (excluding Canada)
  • Communicate and liaise with other global tax members on new balance sheet transactions involving cross border dealings
  • Assist with responding to revenue authority queries where required in audit
  • Assist with decision support regarding tax attributes and tax capacity
  • Assist in the review and preparation of statements and notices
  • Review US tax returns in relation to technical positions taken
  • Review and negotiate the tax provisions in ordinary course business agreements (loan agreements, purchase agreements, GMRAs, ISDAs, etc.)

KEY SKILL REQUIREMENTS

Business Knowledge

  • Demonstrate broad commercial knowledge, which extends to the financial services industry
  • Ability to develop and maintain strong internal client relationships with business unit executives and external relationships with advisors
  • Ability to respond to internal and external tax questions in a timely and professional manner
  • Ability to form a technical view and make timely decisions, within the parameters set for the role, and discuss those views with senior members of the Tax Advisory Team
  • Demonstrate a commercial focus
  • Ability to explain complex concepts to non-tax business professionals and other stakeholders

Technical Specialist Skills

  • Federal income tax knowledge reflective of 5-7 years of experience
  • Quantitative and Excel spreadsheet skills
  • Superior research skills

Planning & Organizing

  • Well-organized and able to coordinate multiple assignments and successfully manage work plans
  • Actively take responsibility and ownership for corporate tax technical issues impacting the Group
  • Open communication of issues to his/her Manager and the Americas Head of Tax
  • Ability to support other Tax Division members globally when situations arise to ensure requirements and goals are met
  • Flexible approach to process change

QUALIFICATIONS & BACKGROUND

  • University degree.  Preference is for candidates with a law degree, but strong candidates with an accounting degree will also be considered (particularly if they have also completed a Masters of Tax).

 

Contact A Stan Hamlet Associate: 212.685.4884

Director of International Tax – Global Media and Entertainment Company

Director of International Tax –    Global Media and Entertainment Company–250-300k plus bonus

The International Tax Director contributes to the Company’s success by managing critical work streams necessary for the effective operation of the global tax function including planning, compliance, and tax accounting in accordance with US GAAP.

Develop strong working relationships with business, finance, and tax leaders across the global organization to collaborate on significant tax matters affecting the Company’s operations outside the U.S.

Perform critical research and analysis related to global tax planning initiatives, mergers and acquisitions, cross-border transactions, transfer pricing, and tax credit opportunities

Analyze US and non-US tax impacts of international transactions to determine impact on the Company’s global taxes

Proactively work with businesses to structure their operations to promote tax efficiency and mitigate tax risk

Strong expertise in US international tax particularly with hybrid entities, check-the-box planning, US tax attributes of foreign subsidiaries, foreign inclusions under Subpart F, and foreign tax credit utilization

Maintain all calculations, documentation, and support related to US international tax attributes of foreign subsidiaries; responsible for the analyses of non-US transactions and related impacts on US taxes, including the determination of US foreign inclusions under Subpart F, foreign dividends, and foreign tax credits

Work closely with corporate treasury to efficiently manage deployment of overseas cash and repatriation strategies

Actively engage in quarterly financial reporting processes; prepare analyses of US foreign inclusion items and provide assistance and review of income tax provisions related to significant international subsidiaries in accordance with US GAAP

Responsible for managing the accurate and timely preparation of all US tax filings related to the Company’s international operations

Work collaboratively with outside advisers on significant tax projects

Provide technical support related to tax audits and perform critical analysis to build audit defense strategies

Develop and provide direction on global tax policies and processes to help foster a strong control and governance environment within the tax function

Desired Skills and Experience

10+ years of progressive tax experience with emphasis on US Federal and non-US taxes

Experience with a Big 4 accounting firm or large multi-national organization or a combination of both

CPA certificate required

Masters Degree in Taxation or JD/LLM in Tax is desirable

Extensive international tax expertise

A demonstrated ability to self-direct and effectively organize and prioritize under tight deadlines

Ability to think critically to resolve complex issues and challenges

Excellent project management and presentation skills required

Excellent research, analytical, organizational and written/verbal communication skills

Great interpersonal skills; ability to establish and build partnerships with different departments, business partners and management

Team player that cultivates collaboration and leadership throughout the global tax organization

Contact A Stan Hamlet Associate: 212.685.4884

VP of International TAX- Global Media and Entertainment Company

VP of International TAX–  Global Media and Entertainment Company– NYC  350-400k –

The Vice President, International Tax contributes to the Company’s success by providing strategic direction and tactical support on tax matters globally.

Develop strong working relationships with business, finance, and tax leaders across the global organization to collaborate on significant tax matters affecting the Company’s operations outside the U.S.

Lead strategic tax planning related to the Company’s global operations and tax structure including mergers and acquisitions, cross-border financing, transfer pricing, and tax credit opportunities

Proactively work with businesses to structure their operations to promote tax efficiency and mitigate tax risk

Oversee international tax operations in areas of compliance, cash management, tax provisioning, and audits

Strong expertise in US international tax particularly with hybrid entities, check-the-box planning, US tax attributes of foreign subsidiaries, foreign inclusions under Subpart F, and foreign tax credit utilization

Actively engage in quarterly financial reporting processes and advise on the impact of international transactions on the global tax provision

Monitor significant tax legislation and developments globally and advise of the impact on the Company’s taxes

Review US tax filings for completeness and technical accuracy including proper elections and disclosures

Review legal agreements, step plans, and documentation to ensure tax requirements are met

Review and document uncertain tax positions affecting the US and non-US tax provisions

Provide strategic support and assist with the development and review of relevant tax audit information requests

Work closely with and manage US and non-US tax advisers on significant tax projects

Develop and provide direction on global tax policies and processes to help foster a strong control and governance environment within the tax function

Desired Skills and Experience

15+ years of progressive tax experience with emphasis on U.S. Federal and non-U.S. taxes.

Experience with a Big 4 accounting firm, large multi-national organization, or law firm(or combination thereof

CPA certificate required

Masters Degree in Taxation or JD/LLM in Tax is highly desirable

Extensive international tax expertise is essential

Strong communications skills and ability to explain complex technical concepts in a simple and succinct way to non-tax internal constituents is essential

Ability to think critically to resolve complex issues and challenges

Transparency; the ability to communicate up and down the organization, respecting differing views and reducing potential surprises

Ability to build relationships and work effectively with internal clients and external advisors

Well-developed organizational, time management, planning and prioritization skills

Team player that cultivates collaboration and leadership throughout the global tax organization

Contact A Stan Hamlet Associate: 212. 685. 4884

Manager International Tax Planning – 125-140k

This person will conduct foreign and US international tax planning for (1) ongoing operations of the company, (2) potential acquisitions and dispositions, and (3) other special tax projects. The following specifications are required for this position:
• Ability to manage and oversee the successful implementation of large, complex tax restructurings

• Work on Transfer Pricing and utilize transfer pricing policy are part of an overall global tax strategy to reduce the Company’s effective tax rate

• This person will assist in the preparation, documentation and strategy during US international and foreign tax audits

• The individual should have in-depth knowledge of US and foreign tax law, including experience with researching US international tax issues

• Experience including but not limited to Subpart F, repatriation of earnings, foreign tax credit planning & utilization and transfer pricing is required

• Ability to review international aspects of US tax return (5471, 1118 etc), E&P schedules, Subpart F, and foreign tax credit calculations

• Ability to model different aspects of planning opportunities

• A general ability to use sound judgment and interpersonal skills to obtain and determine the source, timing, significance and effective use of tax data is also necessary

• Gather information which will allow financial forecast and modeling of the effective tax rate with a particular focus on reducing cash taxes and the effective tax rate

• Draft responses to IDR’s related to Federal and international tax audits

MINIMUM QUALIFICATIONS:
• Bachelor’s degree in accounting or JD (masters in taxation or LLM a plus)
• Minimum 4 years of international tax experience which should include Big 4 public accounting firm or law firm & large multinational corporate tax department
• Strong PC knowledge and skills using Microsoft Office applications; ability to do modeling of planning opportunities
• Strong interpersonal skills and excellent oral and written communication skills

PREFERRED QUALIFICATIONS:
CPA or JD with Masters degree in taxation preferred or LLM
Big Four or Law firm Tax Experience preferred
Self motivated; ability to work alone and as part of a project team
Strong interpersonal skill; the ability to communicate well and develop relations internally and externally
Ability to drive results
Highly organized with the ability to manage multiple projects at one time
Ability to see beyond tax borders

Contact A Stan Hamlet Associate: 212-685-4884