The candidate's primary responsibilities will include the following: Review ongoing and new business activities and provide advice on the tax consequences, risks and opportunities; Work closely with the Senior Transfer Pricing Manager to address global transfer pricing policy issues and audits; Repatriation planning to bring cash to the U.S. in a tax effective manner; Provide tax planning advice and assist with tax modeling for M&A and other material Company transactions, including integration planning and execution; Ensure tax implications of M&A and other material transactions are reflected into Company's tax provision and U.S. tax returns; Partner with the international tax team to drive effective foreign country tax planning; Research and draft memoranda documenting positions taken, preparation of FIN 48 analyses and presentations for any tax authority negotiations; Manage outside tax advisors and counsel to bring in expertise required for arriving at optimal solutions/decisions; and Stay informed of major U.S. tax developments.
The candidate should have JD degree with 5-7 years of experience at a law firm or Big 4 accounting firm or Fortune 6500 company working in U.S. international corporate tax law and transfer pricing; Experience with repatriation, foreign tax credits, M&A, Subpart F, and transfer pricing; Must have strong analytical skills with proven ability to solve multidimensional problems creatively; Strong written, verbal and interpersonal skills and the ability to collaborate with business and functional leaders across the company; and Highest standards of integrity, business controls, and business practices.
Senior Tax Counsel
The candidate will have accountabilities for regional and global tax planning. This will include working on cross boarder capital and legal entity structuring projects, M&A, joint ventures as well as dispositions. Assist on Tax planning, Tax controversies, Tax training, Tax reporting and compliance. Should have 10+ years of tax planning experience.
Senior Manager, Tax Counsel
Responsibilities: The candidate will be Providing tax analysis and legal support to the VP-Taxes, other tax personnel, and operations executives. Evaluating the technical merits of internally and externally developed tax strategies, identifying issues and opportunities, and presenting conclusions and recommendations both orally and in writing. Staying abreast of changes in U.S. federal tax law as well as the tax law in key foreign jurisdictions and developing strategies to exploit opportunities, avoid pitfalls, and ensure adequate and efficient compliance. Advising senior corporate and operations executives regarding tax efficient methods of accomplishing acquisitions and dispositions, assisting in the drafting of related agreements, and performing associated legal and financial due diligence. Working closely with domestic and foreign treasury personnel to manage intercompany funding requirements, including leverage planning and repatriation strategies. Managing and assisting with federal, state and local, and foreign tax controversies (audits and litigation). Managing relationships with outside advisors regarding planning, return preparation, and audits. Ensuring that tax planning initiatives are properly recorded for tax accounting and financial reporting purposes. Evaluating the financial accounting implications of uncertain tax positions and recommending appropriate FIN 48 reserves.
Requirements: The candidate should have 7 years of experience related to tax research and planning with a prominent law firm or accounting firm. A background in finance or accounting is a plus. Have an excellent foundation in federal corporate income tax analysis, particularly subchapter C (corporate organizations, liquidations, distributions, and reorganizations), subpart F, foreign tax credit planning, withholding taxes, transfer pricing, hybrid entities and instruments, and bi-lateral tax treaties. A basic understanding of consolidated return issues, state and local issues, and federal practice and procedure is useful but not required. Have provided tax advice relating to acquisitions and dispositions and participated in the diligence process. Have strong academic credentials. Be able to apply technical tax rules in a practical business environment. Be an exceptional communicator, able to build relationships and deal effectively across functional lines. Be a proactive self-starter who is comfortable identifying tax issues, forming and proposing solutions, and following through to ensure proper reporting and implementation.
Duties: International tax planning. This individual will assist in developing creative tax strategies to reduce Marsh & McLennan Companies' global effective tax rate and maximize cash flow opportunities; implement internal corporate reorganizations; develop tax audit positions to minimize tax liabilities; provide documentation for company tax positions; undertake international, federal, and state tax research as necessary, and provide analytical (financial modeling) support and accounting support, among other projects. Managing external mergers and acquisitions and dispositions. This individual should have heavy experience in the M&A area and will be the "face" of the Tax Department toward the Corporate Development group. This individual should be able to spot opportunities for tax-effective acquisition financing, tax-efficient acquisition vehicles and structures, and post-acquisition planning and restructuring.
Qualifications: JD Degree required, plus LL.M. (Master in Law) optional. 10-15 years' experience. Highly competent international tax planning and M&A professional.
Tax Counsel - -International
Responsibilities: Analyzes foreign transactions and business activities to identify tax issues and recommend advantageous actions, terms, or structures; identifies and implements tax-saving opportunities and projects; and advises on compliance and reporting requirements. Serves as company's subject matter expert on the U.S. tax consequences of cross border transactions and foreign operations. Analyzes and coordinates tax consequences of transactions in multiple jurisdictions. Develops and implement advantageous strategies/structures and tax planning/savings opportunities, including identification and calculation of potential exposure items and preparation of defense. Provides U.S. international tax research, analysis, and advice on transaction terms/contracts. Advise son U.S. international tax positions based on tax research and analysis as well as legal, business, and practical considerations. Manages tax due diligence on potential foreign acquisitions. Reviews relevant tax returns and advise on tax reporting of foreign transactions with significant tax consequences. Reviews and assists with foreign reporting obligations. Partners with Strategic Finance, Mergers and Acquisitions, Treasury, Legal, and other departments to incorporate tax strategies into business plans and manage cash tax liabilities. Provides U.S. and foreign tax analysis for the international tax provision, FIN 48 reserves, and Sarbanes-Oxley requirements. Assists with tax audits, U.S. and foreign. Monitors U.S. international tax law changes and major foreign law changes to determine the effect on business activities and recommend any needed response to those changes.
Qualification Requirements: A J.D. degree with substantial tax law coursework required (including international tax). Undergraduate or Masters of Accounting or equivalent, CPA certification, and/or LL.M. degree is desired. Must have 8+ years in a corporate tax department or major law or accounting firm, including 4+ years of experience in international tax planning for multinational corporations required. Supervisory experience and experience with tax controversies desired. Must have extensive knowledge of Federal tax law; working knowledge of foreign direct and indirect tax rules. Ability to identify and analyze tax issues and recommend solutions; and the ability to convey technical tax advice to executives in a manner that enables them to interpret the underlying issues and make business decisions. Spanish language skills a plus.
Part-time Tax Counsel
The candidate will primarily support firm's Corporate and Government Contracts practices, although will often be consulted by lawyers firm-wide. The day-to-day focus will be to advise clients on federal tax matters, primarily transactional matters, and to structure and negotiate business transactions.
The candidate should have 8+ years of demonstrated experience with tax aspects of corporate and partnership transactions, including taxable and tax-free equity and asset transactions. Must also have experience with tax controversies, tax-exempt entities, tax compliance, and general income tax accounting issues. Must have excellent academic credentials and references.