Director, US International Tax
Leads US international tax provision, compliance, reporting, and planning for a rapidly expanding technology company. The role requires deep expertise in international tax rules and ASC 740, experience across Big Four and in-house environments, and the ability to build scalable processes and controls.
About the job
Responsibilities
- Own the US international components of the quarterly and annual worldwide income tax provision, including NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credits, Section 861 expense allocation and apportionment, E&P, and PTEP tracking.
- Own outside basis difference analysis and indefinite reinvestment assertions under ASC 740-30, along with US international aspects of valuation allowance and uncertain tax position assessments.
- Design and operate SOX controls over the international provision process and support financial statement audits.
- Lead preparation and review of US international tax return workpapers and forms, including Forms 5471, 8992, 926, 1118, 8858, 8865, 8991, and 8993.
- Support US withholding tax compliance 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 with US international tax modeling for market entry, entity structuring, intercompany and transfer pricing arrangements, financing, and M&A.
- Monitor and model legislative and regulatory developments, including OBBBA implementation guidance and Pillar Two interaction with the US system.
- Manage outside advisors, support audit defense and controversy, and mentor and develop tax team members.
Requirements
- Substantial US international tax experience in multinational software and technology companies, combining Big Four and in-house corporate tax experience.
- Deep technical command of US international tax law, including NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credits, E&P/PTEP, Section 861 allocation, and ASC 740, including ASC 740-30 outside basis analysis.
- Experience owning both provision and compliance functions at scale, with reviewer-level knowledge of Forms 5471, 8858, 8865, 1118, 8991, 8992, and 8993.
- CPA and/or JD required.
- Ability to communicate complex technical positions clearly to auditors, executives, and non-tax partners.
- Ability to work as the sole authority in a high-growth, ambiguous environment.
Nice-to-haves
- Master's in Taxation or LLM.
- Pillar Two data and modeling experience and knowledge of its interaction with US rules.
- Experience with tax aspects of large, novel commercial arrangements, including infrastructure and compute agreements, strategic investments, or complex equity structures.
- Hands-on tax technology experience and interest in applying AI tools to tax workflows.
- Pre-IPO readiness or public-company reporting experience at a multinational software company.
- M&A experience spanning diligence, structuring, purchase accounting, and post-close integration.
Compensation and Benefits
- Annual salary: $230,000–$300,000 USD.
- Hybrid policy: Staff are generally expected to work from an office at least 25% of the time; some roles may require more office time.
- Visa sponsorship may be available.
Skills
Us International Tax, Ncti/Gilti, Subpart F, Fddei/Fdii, Beat, Foreign Tax Credits, Asc 740, Sox Controls, Transfer Pricing, Pillar Two, Tax Technology, M&A, CPA, Jd
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