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 partnershipsBuy/sellRestructuringsDebt financed distributionsCash repatriation and dividend planningTransactions involving members of a U.S. consolidated tax groupOut from under planningDebt modification/refinancing including unwinding intercompany loansDebt vs. equity analysis Third-party buy/sell structuring Stock vs. assets sale/buyModeling338(g)/336(e)/338(h)(10) electionsInstallment sale planningRestructures prior to the salePost-purchase restructuringPlanning 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 collectingMinimum Qualifications:Juris Doctor (preferably with an LL.M. in Taxation) and/or CPA8 years or more of transactional/consulting experience in a law firm or CPA firmStrong analytical, research, computational, writing, and planning skills#LI-SS1 #LI-CLTSP #LI-ATL