Sr. Manager, International Tax
St. Louis, MO
Responsible for the U.S. And foreign tax consequences of the Company' s international transactions and operations. This includes responsibility for structuring, implementing, and reporting of transactions with minimum overall tax costs. In addition, responsibilities include managing the international aspects of US income tax compliance for the Company's non-US business operations. Assist in analyzing the worldwide tax impact of movement of non-US cash and new statutes enacted as part of US tax reform in 2017 (e.G., FDII, GILTI, and BEAT).
Act as advisor to corporate management regarding proposed acquisitions, liquidations, and other corporate restructuring.
Provide corporate management with tax advice and assistance in structuring and implementing international operations and transactions.
Provide tax advice and assistance to business unit management in structuring their operations and executing their transactions while optimizing overall tax costs.
Assist in repatriating foreign cash through dividends, ensuring that all legal obligations have been met and the tax cost (US and non-US) of such dividends have been analyzed and minimized.
Manage international aspects of US income tax compliance:
Review for possible U.S. Income inclusions as a result of subpart F and GILTI rules.
Review and analyze current E&P and tax pool calculations.
Oversee the filing of related interntional tax forms. (5471, 8858, etc.)
Review the Form 1118 and related schedules pertaining to the Company's consolidated foreign tax credit calculation.
Review and analyze proposed and enacted changes in U.S. And foreign tax laws, regulations, and court cases and provide timely updates to management.
Assist in the review of income tax rate analysis (expected and actual). Assist with ASC 740 reporting requirements for foreign entities as they relate to income inclusions from non-US entities (i.E. Subpart F, GILTI, dividends, etc.).
Provide the internal treasury group with tax advice and assistance related to financing structures, changes in capital structures, and other treasury related matters including foreign currency and hedging analysis.
Supervise and manage the international section of U.S. Tax audit, as well as international tax audits and controversies in tandem with other corporate tax teams.
Prepare and execute requests for rulings, refund claims, etc. And/or act as liaison with respect to same with U.S. And foreign tax matters.
Organize and manage the Company' s international tax program to:
Develop and implement international tax proposals.
Assist with and support compliance with foreign laws and regulations. (Including tax returns, annual reports, statutory filings, etc.)
Assist in the establishment of tax procedures and reporting policies for foreign corporations. (including subsidiaries, joint ventures, and exports)
Provide tax support and advice concerning international benefits, expatriate taxation, and other non-US social taxes.
Assist in the identification and implementation of computer software which will more efficiently feed international tax information into the federal income tax return process.
Coordinate, review, and verify statutorily required documentation for intercompany transactions between US and non-US legal entities.
B.S. In Accounting or other Bachelor's Degree required.
J.D. And/or CPA preferred
Minimum of 5-10 years tax experience with a CPA firm or Fortune 300 company with multidivisional structure and progressively responsible tax experience with a corporate tax department and/or licensed public accounting firm.
Preferably with two or more years in international tax.
Knowledge of HFM, OneSource, Tax Stream or similar systems, a plus.