General information

Name
Consulting - Tax Specialty - Senior Manager - M&A & International Tax
Posting Title
Senior Manager | M&A & International Tax
Ref #
2228648
Date Published
Thursday, August 10, 2023
City
Charlotte
State
North Carolina
Country
United States
Job Category
Tax Specialty
Office
International Tax
Advertised Location
US-GA-Atlanta, US-NC-Charlotte
Working time
Full Time

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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