Senior Manager | M&A & International Tax

Company Profile:

At FORVIS, your career is designed with a purpose. We want our team members to thrive professionally and feel the impact their work yields when serving clients, industries, and local communities. This starts by empowering team members to design a career journey that leverages their skills and fuels their passions.

Creating a best-in-class employee experience is at the heart of our vision for the future. With several industry focus areas, multiple service lines, and locations in five geographical regions across the country to choose from, the opportunities for your career are without limit.

About FORVIS

FORVIS is a Top-10 professional services firm providing assurance, tax, and advisory services, driven by our commitment to using our forward vision to provide rewarding career opportunities and deliver unmatched client experiences. Learn more at FORVIS.com

Design your career with purpose at FORVIS. For more information about our firm locations, visit FORVIS.com. FORVIS, LLP is an equal opportunity/affirmative action employer. Employment selection and related decisions are made without regard to age, race, color, sex, sexual orientation, national origin, religion, genetic information, disability, protected veteran status, or other protected classifications.

It is FORVIS's standard policy not to accept unsolicited referrals or resumes from any source other than directly from candidates.

• FORVIS expressly reserves the right not to consider unsolicited referrals and/or resumes from vendors including and without limitation, search firms, staffing agencies, fee-based referral services, and recruiting agencies.
• FORVIS further reserves the right not to pay a fee to a recruiter or agency unless such recruiter or agency has a signed vendor agreement with FORVIS.
• Any resume or CV submitted to any employee of FORVIS without having a FORVIS vendor agreement in place will be considered the property of FORVIS.

Requisition Number: 2228648

Position Title:

External Description: Description & Requirements

Office: Open - Preferably Charlotte, NC but open to other major areas in our Geographic footprint, including Atlanta, GA, and Tysons, VA.

FORVIS 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

#LI-SS1 #LI-CLTSP #LI-ATL

#LI-SS1

City: Charlotte

State: North Carolina

Community / Marketing Title: Senior Manager | M&A & International Tax

Location_formattedLocationLong: Charlotte, North Carolina US

CountryEEOText_Description:

At FORVIS, your career is designed with a purpose. We want our team members to thrive professionally and feel the impact their work yields when serving clients, industries, and local communities. This starts by empowering team members to design a career journey that leverages their skills and fuels their passions.

Creating a best-in-class employee experience is at the heart of our vision for the future. With a global presence and diversified service offerings, we provide our FORVIS team members with an abundance of career paths to choose from. We pride ourselves on building an inclusive culture where the backgrounds and talents of all our people are valued. We view our people as our most important asset and invest in them by providing competitive total rewards, professional development, and rewarding career opportunities.

About FORVIS

FORVIS is a professional services firm providing assurance, tax, and advisory services. Created by the merger of equals of BKD, LLP and Dixon Hughes Goodman, LLP (DHG), FORVIS is driven by the commitment to use our forward vision to deliver Unmatched Client Experiences™. Ranked among the top 10 public accounting firms in the country, FORVIS has 5,500 dedicated professionals who serve clients in all 50 states as well as across the globe. FORVIS is built upon the strong legacies of BKD and DHG, which are reflected in a name that comprises partner initials and represents our unique focus on preparing our clients for what is next. Visit forvis.com for additional information.

FORVIS, LLP is an equal opportunity/affirmative action employer. Employment selection and related decisions are made without regard to age, race, color, sex, sexual orientation, national origin, religion, genetic information, disability, protected veteran status, gender identity, or other protected classifications.

It is FORVIS's standard policy not to accept unsolicited referrals or resumes from any source other than directly from candidates.

• FORVIS expressly reserves the right not to consider unsolicited referrals and/or resumes from vendors including and without limitation, search firms, staffing agencies, fee-based referral services, and recruiting agencies.
• FORVIS further reserves the right not to pay a fee to a recruiter or agency unless such recruiter or agency has a signed vendor agreement with FORVIS.
• Any resume or CV submitted to any employee of FORVIS without having a FORVIS vendor agreement in place will be considered the property of FORVIS.