Senior Manager of International Tax

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As Senior Manager – U.S. International Tax, you’ll lead and manage all aspects of U.S. international tax compliance, transfer pricing, and international tax accounting under ASC 740. This role is a key member of the tax leadership team and will serve as a strategic advisor to finance, legal, treasury, and business partners on cross-border tax matters. The position requires deep technical expertise, strong judgment, and the ability to operate effectively in a complex multinational environment, including partnership structures and public company reporting requirements. The role requires someone dedicated to the continuous improvement of existing processes, technology solutions and documentation. The ideal candidate will be a team player with a highly analytical mindset, strong work ethic, extreme attention to detail with a desire to provide quality service to internal and external stakeholders and help build a best in class tax function.

What you’ll do

Global Minimum Tax (BEPS Pillar Two / GLoBE)

• Lead the implementation and ongoing compliance with BEPS Pillar Two (GLoBE) requirements across relevant jurisdictions.
• Oversee calculation of jurisdictional effective tax rates and top-up taxes under GLoBE rules, including income inclusion rule (IIR), undertaxed profits rule (UTPR), and qualified domestic minimum top-up taxes (QDMTT).
• Manage data collection, validation, and reporting processes required for GLoBE compliance, including coordination with finance, IT, and external advisors.
• Evaluate the impact of Pillar Two on the company’s global tax profile, including interaction with U.S. tax rules (e.g., GILTI, FTCs).
• Support development and documentation of accounting positions related to Pillar Two, including ASC 740 implications and required disclosures.
• Monitor global legislative adoption and ensure timely implementation of new country-specific requirements.

International Tax Accounting (ASC 740)

• Lead the international components of the income tax provision, including calculation of GILTI, Subpart F, FTCs, and other cross-border impacts on the effective tax rate.
• Incorporate BEPS Pillar Two impacts into the tax provision, including current and deferred tax considerations, policy elections, and disclosure requirements.
• Analyze and document tax positions related to outside basis differences (including partnership investments), indefinite reinvestment assertions, and valuation allowance considerations.
• Support quarterly and annual reporting, including ETR drivers, return-to-provision adjustments, and tax footnote disclosures.
• Coordinate with external auditors and internal stakeholders to support audit requirements and technical position documentation.
• Evaluate and document uncertain tax positions (ASC 740-10), including those related to international and Pillar Two matters.

U.S. International Tax Compliance

• Lead the preparation and review of U.S. international tax compliance, including Forms 5471, 5472, 8858, 8865, 1118, and related disclosures.
• Oversee calculations related to GILTI, Subpart F income, FDII, BEAT, foreign tax credits (including FTC limitation and carryforwards), and earnings & profits (E&P).
• Manage and review work performed by external advisors to ensure accuracy, completeness, and alignment with internal positions.
• Coordinate with domestic tax and provision teams to ensure consistency between compliance and financial reporting.
• Monitor legislative and regulatory developments (U.S. and OECD), including BEPS initiatives, and assess implications to the company.

Transfer Pricing

• Oversee the design, implementation, and governance of global transfer pricing policies in alignment with business operations and OECD guidelines.
• Manage preparation and review of transfer pricing documentation (Master File, Local Files, Country-by-Country reporting).
• Partner with finance and operations to operationalize intercompany agreements and ensur