Overview
Lead US international tax reporting and compliance for a global income tax provision and end-to-end US international compliance program. Act as the technical authority on US international tax rules, building calculations, controls, and the team.
What you'll do
- Own quarterly and annual US international components of the worldwide income tax provision, including NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credit computations, and Section 861 expense allocation and apportionment.
- Perform outside basis difference analysis and indefinite reinvestment assertions under ASC 740-30.
- Design and operate SOX controls over the international provision process and support the financial statement audit.
- Prepare and review US international tax return workpapers and forms including 5471, 8992, and 926 (expanding to 1118, 8858, 8865, 8991, and 8993).
- Support US withholding tax compliance (Forms 1042/1042-S) and cross-border payment analysis.
- Build a compliance calendar, data pipelines, and review procedures; drive automation and tax technology adoption (including AI tooling).
- Assist tax planning and M&A teams by modeling US international tax consequences for new market entry, structuring, intercompany/transfer pricing, financing, and M&A.
- Monitor legislative and regulatory developments (including Pillar Two interaction and OBBBA implementation guidance) and model provision and cash tax impacts.
What you'll need
- Have substantial US international tax experience in multinational software and technology companies.
- Have deep technical command of US international tax law covering NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credits, E&P/PTEP, and Section 861 allocation.
- Have ASC 740 expertise for the listed international items, including ASC 740-30 outside basis analysis.
- Have owned provision and compliance sides of a US international tax function at scale, with reviewer-level command of Forms 5471, 8858, 8865, 1118, 8991, 8992, and 8993.
- Hold a CPA and/or JD; a Master’s in Taxation or LLM is a plus.
- Communicate complex technical positions clearly to auditors, executives, and non-tax partners, including acting as sole authority.
Details
- Employment is described as a leadership role in a team expanding US international footprint, reporting to the global provision lead.
- Hybrid policy: expected to be in one of the offices at least 25% of the time.
- Visa sponsorship is available and the company makes reasonable efforts to support candidates if offered.
