- Candidate must have a strong transactional tax background (focused on inbound and outbound international acquisitions, dispositions, financings, reorganizations (acquisitive and divisive), restructurings, and joint ventures) and 10 years of experience in this area that includes (1) working with U.S. inbound and outbound rules (including rules dealing with CFCs, foreign tax credits, FIRPTA, income sourcing, etc.); (2) working with the rules in Subchapter K, Subchapter C, and the consolidated return regulations and applying them to international fact patterns; (3) structuring and documenting complex international M&A transactions; (4) drafting tax memoranda, opinions, and ruling requests; (5) reviewing transaction documents and drafting tax provisions; (6) reviewing and commenting on the tax aspects of financial models; (7) managing external non-U.S. tax counsel and be able to understand and communicate non-U.S. tax issues discussed with counsel; (8) providing management, development, and career support to team members; (9) communicating complex tax technical issues to Senior Management and internal/external stakeholders; and (10) overseeing critical business operations with minimal direct supervision. The candidate also must have strong leadership and interpersonal skills, including the ability to coordinate effectively with various subject matter specialists and proactively manage internal stakeholder relationships.
- Two (2) years of experience preferred working on M&A tax issues at an AmLaw 100 law firm or in the M&A group or Washington National Tax office of a "Big 4" public accounting firm. Energy industry preferred, but not required.
Drive value by providing support to deal teams and business units throughout the organization with respect to the U.S. and non-U.S. tax aspects of international acquisitions, dispositions, financings, reorganizations (acquisitive and divisive), restructurings, and joint ventures, with a view to optimize taxes. Provide SME support for U.S. taxes arising from these transactions; manage external non-U.S. tax counsel and be able to understand and communicate non-U.S. tax issues discussed with counsel. Serve as the international tax single point of accountability and be able to identify non-international tax issues to be addressed by applicable SME. Work with Governmental Affairs, Investor Relations, and Communications to promote the Company's legislative priorities and assist with communications. Effectively communicate complex technical tax issues to Senior Management and internal/external stakeholders, including the broader finance business unit. Negotiate and draft tax provisions in deal documents and prepare technical tax memoranda. Manage and develop team members. Exhibit sound business judgment in a fast-paced work environment with ability to manage and prioritize various responsibilities and deliverables.
- Bachelor's Degree (B.S. or B.A.)
- Master of Laws in Taxation (LL.M.)
- Member in Good Standing of a State Bar (U.S.)
Member in Good Standing of State Bar:Yes;Juris Doc:Required;LLM - Master of Laws:Required;Bachelor's Degree:Required;Experience:7 years;