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Senior Associate/ Manager, Global Transaction Tax (International M&A Tax)
3 years ago

A&M's Global Transaction Tax team consists of seasoned tax professionals experienced in providing practical tax advice to corporate and private equity clients throughout the transaction life cycle. By working alongside A&M professionals with deep operating and financial-related experience, the team uses a focused and tailored approach to rapidly identify and understand potential deal breakers, value drivers, and other areas of specific interest to our clients.

Our Global Transaction Tax Services Include

  • Performing tax due diligence, including reviewing target's historic tax profile, planning, tax examinations, acquisitions/dispositions, and filing history to assess potential risks and opportunities

  • Using the due diligence process to identify opportunities for further tax efficiencies

  • Evaluating potential acquisition structures and structuring transactions in a tax-efficient manner

  • Reviewing and evaluating significant tax attributes, credits and incentives

  • Reviewing and commenting on purchase agreements and disclosure schedules

  • Modeling transaction scenarios

  • Identifying matters to be addressed post-closing, including integration related risks and opportunities

Responsibilities

  • Provide US international tax advice to GTT teams performing tax due diligence, transaction structuring, ;

  • Structuring cross border transactions in a tax-efficient manner and providing commentary on the effectiveness of proposed acquisition structures

  • Modeling transaction scenarios and assisting GTT teams in quantifying the impact Section 904, Sections 951/ 951A, Section 59A, Section 163(j). and Section 250, including modeling the tax expense impact of these and other tax reform provisions

  • Identifying post acquisition opportunities, including foreign tax credit and repat planning, post acquisition integration planning, etc.

  • Research technical issues and draft PPTX and memoranda pertaining to international issues, reorganizations, and restructurings

  • Work with foreign offices and other GTT and transfer pricing team members to deliver the highest quality integrated work product

  • Assist with global project management and identification of cross-border tax issues (i.e., withholding tax, BEAT, inversions, hybrid mismatch rules etc.)

Qualifications

  • BBA, with Major in Accounting preferred

  • Advanced Certification required: CPA, or Bar Admittance

  • 4-6+ years of US international tax experience servicing US partnered multinationals

  • Professional transaction tax experience - i.e., Subchapter C - a must; Subchapter K (partnerships) experience - a plus

  • Understanding of inbound and outbound international tax planning strategies and concepts (i.e., check the box, treaty qualification, FIRPTA, supply chain models, etc.)

  • Strong writing, analytical, research and organizational skills

  • Proficient in Microsoft Excel preferred

  • Strong communication skills

  • Strong sense of personal motivation as well as the ability to work with a team

  • Ability to work in dynamic, time-sensitive environment

Diversity & Inclusion

A&M's entrepreneurial culture celebrates independent thinkers and doers who can positively impact our clients and shape our industry. The collaborative environment and engaging work-guided by A&M's core values of Integrity, Quality, Objectivity, Fun, Personal Reward, and Inclusive Diversity-are the main reasons our people love working at A&M. Inclusive Diversity means we embrace diversity and we foster inclusiveness. It runs through how we recruit, develop employees, conduct business, support clients, and partner with vendors. It is the A&M way.

Voluntary Inclusion

It is Alvarez & Marsal's policy to provide and promote equal opportunity in employment, compensation, and other terms and conditions of employment without discrimination because of race, color, sex, sexual orientation, gender identity, family medical history or genetic information, political affiliation, military service, pregnancy, marital status, family status, religion, national origin, age or disability or any other non-merit based factor in accordance with all applicable laws and regulations.

Unsolicited Resumes from Third-Party Recruiters

Please note that as per A&M policy, we do not accept unsolicited resumes from third-party recruiters unless such recruiters were engaged to provide candidates for a specified opening. Any employment agency, person or entity that submits an unsolicited resume does so with the understanding that A&M will have the right to hire that applicant at its discretion without any fee owed to the submitting employment agency, person or entity.






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