Senior Manager | M&A & International Tax
Charlotte, North Carolina
Employer: FORVIS
Industry:
Salary: Competitive
Job type: Full-Time
Description & Requirements
Forvis Mazars is seeking an M&A and international tax senior manager/director 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:
Minimum Qualifications:
#LI-BOCR, #LI-ATL, #LI-OAK, #LI-CLTSP, #LI-DFW, #LI-HOU
#LI-SS1
Forvis Mazars is seeking an M&A and international tax senior manager/director 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-ATL, #LI-OAK, #LI-CLTSP, #LI-DFW, #LI-HOU
#LI-SS1
Created: 2024-08-27
Reference: 2232813
Country: United States
State: North Carolina
City: Charlotte
ZIP: 28269
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