Senior Manager | M&A & International Tax

Description & Requirements

Forvis Mazars is seeking an M&A and international tax senior manager/director within a fast-growing public accounting firm serving a broad range of clients from middle-market companies to publicly traded corporations.

How you will contribute:

• Managing restructuring and M&A transactional projects from a U.S. federal income tax perspective. Such projects could include purely domestic transactions as well as transactions involving foreign entities. Thus, the candidate should have a solid understanding of the corporate non-recognition tax rules, the U.S. consolidated return tax rules, the partnership tax rules, and the U.S. international tax rules.

• Typical projects managed could include the following (domestic and/or foreign):

• Corporate restructuring of legal entities in a tax-deferred manner (e.g., IRC section 351, 332, 368, 355, 367, etc.)

• Legal Entity Rationalizations ("LERs")

• E&P studies (including U.S. consolidated tax group and foreign entities).

• Tax basis studies (i.e., tax basis of stock including U.S. consolidated tax groups or tax basis of assets)

• Worthless stock deductions (including in a U.S. consolidated group)

• Transactions involving partnerships

• Buy/sell

• Restructurings

• Debt financed distributions

• Cash repatriation and dividend planning

• Transactions involving members of a U.S. consolidated tax group

• Out from under planning

• Debt modification/refinancing including unwinding intercompany loans

• Debt vs. equity analysis

• Third-party buy/sell structuring

• Stock vs. assets sale/buy

• Modeling

• 338(g)/336(e)/338(h)(10) elections

• Installment sale planning

• Restructures prior to the sale

• Post-purchase restructuring

• Planning and modeling regarding U.S. international tax rules (GILTI, subpart F, foreign tax credits, BEAT, FDII, IRC sec. 163(j), etc.)

• Treaty analysis

• When not involved in transaction projects, the candidate would be expected to advise on and manage international tax projects (GILTI, Subpart F, foreign tax credits, BEAT, FDII, etc.)

• Responsibilities with respect to the above would include:

• Growing and developing team members,

• Business development,

• Heavy client communications,

• Working with attorneys to execute transactions and reviewing legal documents,

• Issuing slide decks detailing the steps of the transaction(s),

• Working with foreign affiliates for non-U.S. tax consequences,

• Issuing technical memorandums and/or tax opinions,

• Excel modelling of transaction(s),

• Billing and collecting

Minimum Qualifications:

• Juris Doctor (preferably with an LL.M. in Taxation) and/or CPA

• 8 years or more of transactional/consulting experience in a law firm or CPA firm

• Strong analytical, research, computational, writing, and planning skills

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