Description & Requirements

Office: Open - Preferably Charlotte, NC but open to other major areas in our Geographic footprint, including Atlanta, GA, and Tysons, VA.

FORVIS 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

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