Senior Manager, International Tax

Position

Senior Manager, International Tax

Location

Auburn Hills, MI 

About us

PHINIA: Advancing sustainability today, powering carbon-free tomorrow.

At PHINIA, we create premium fuel systems, electrical systems, and aftermarket parts for internal combustion engine (ICE) vehicles and industrial applications. We make sure our products are clean, efficient, and high value because we know the actions that we take today will have a profound impact on the world tomorrow. Our goal? The cleanest ICE technology: carbon-free combustion.

Always, PHINIA puts quality first, continuing our legacy with over a century of rich expertise and technological innovation. The name PHINIA has roots related to “bright” and “future,” representing our confidence and commitment to bettering the world.

Our Culture

We believe the health and safety of our employees are a top priority, we care about our local communities and the global environment. PHINIA promotes and nurtures a diverse and inclusive environment, honors integrity, strives for excellence, commits to responsibility for our communities and the environment, and builds on the power of collaboration.

Career Opportunities

We believe in building a brighter tomorrow for our employees as well as our customers and encourage you to learn about our long history, strong culture, new technologies, and future vision. We offer a strong local presence and interesting global opportunities. Join us on this shared journey toward a brighter tomorrow.

Job purpose

This role will report to the Senior Director, Tax Operations and be responsible for non-US and US international aspects of PHINIA’s US GAAP tax provision as well as assistance with global structuring and compliance activities. This role will also be responsible for the management of key US tax attributes, assistance with the simplification of PHINIA’s legal organization and legacy internal holding and financing arrangements, and continuous improvement initiatives related to non-US and US international workstreams.

Key Responsibilities

• Responsible for calculations of the international aspects of US tax law (BEAT, GILTI, FDII, FTC, Sub F, etc.) and certain non-US aspects of the quarterly global US GAAP tax provision (including Pillar 2 and APB 23) and annual US tax compliance.
• Review all international law aspects of US tax returns prepared by outsourced tax advisors including CbCR, 1118, 5471s, 8858s, 8865s, and disclosures/elections.
• Assist in the preparation and review of non-US tax provisions prepared for US GAAP reporting purposes.
• Oversee transfer pricing policies and documentation to ensure compliance with local and international regulations.
• Monitor changes in global tax laws and assess their impact on the company
• Evaluate the impact of OECD BEPS (Base Erosion and Profit Shifting), Pillar 1 & 2 regulations, and global tax reforms on business operations
• Interface with financial statement auditors and manage the preparation of documentation requested related to non-US and US international tax matters of the tax provision. In addition is responsible for managing the control framework for the US international tax provision processes and adhering to the control framework in all financial statement areas in which they support.
• Owns modeling efforts related to new non-US and US international law provisions
• Ensure proper withholding on cross-border payments (e.g., dividends, interest, royalties, and service fees).
• Works with external providers to track key US tax attributes (PTEP, Basis, 986/987/988 positions, foreign tax credits, etc.)

What we’re looking for

• Minimum of 8 years of relevant international US tax and ASC740 experience and must be able to demonstrate a practical application of that experience.
• Bachelor’s degree in accounting or related field
• CPA and/or MST preferred.
• Strong understanding of OECD tax guidelines, international tax treaties, and transfer pricing rules.
• Experience working with GILTI, FDII, BEAT, CFC rules, and Pillar 2 minimum tax regulations.
• Must have experience of managing others and external advisors on complex tax matters.
• Must have experience of working as part of a cross-functional team, the ability to build relationships with all levels of the organization, and the ability to influence senior stakeholders.
• Must have experience of outlining complex tax issues to senior management.<