Senior Manager | M&A & International Tax - Job at FORVIS in Charlotte, NC

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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