Director, US International Tax Planning

Responsibilities

• Lead US international tax planning projects from analysis through implementation and help prioritize the planning group’s work.
• Analyze tax consequences of new entities and jurisdictions, intercompany arrangements, funding and repatriation, and cross-border commercial and compute agreements; recommend appropriate structures.
• Perform and review technical analyses under Subpart F, NCTI, BEAT, foreign tax credit, expense allocation, and apportionment rules.
• Apply Subchapter C to entity formations, contributions, distributions, liquidations, and internal reorganizations, including earnings and profits and stock basis analysis.
• Define assumptions and scenarios for models measuring cash-tax and effective-tax-rate impacts; review models for technical accuracy and own the resulting conclusions.
• Support post-closing M&A integration through step plans, alternative modeling, and follow-on planning.
• Draft technical memoranda and maintain examination-supporting documentation; coordinate with the provision team on ASC 740 and uncertain tax positions.
• Partner with compliance and transfer pricing teams on intercompany pricing, tax provision, and US international filings, including Forms 5471, 8858, 8991, 8992, and 1118.
• Scope, budget, and manage outside advisors and review their deliverables.
• Track US legislative, regulatory, and OECD developments and communicate impacts to Finance leadership.
• Coordinate with Tax, Legal, Accounting, and Treasury to implement approved planning and integration steps, including intercompany agreements.
• Support IRS and other tax-authority inquiries.

Requirements

• Deep technical knowledge of US international tax provisions, including Subpart F, NCTI, BEAT, and foreign tax credits, with planning experience.
• Working knowledge of Subchapter C for multinational groups, including earnings and profits, stock basis, distributions, and internal reorganizations.
• Experience leading tax planning projects end to end: scoping, analysis, modeling, documentation, and implementation.
• Understanding of how planning positions affect transfer pricing, ASC 740, and US international compliance forms.
• Ability to research the Internal Revenue Code, regulations, and administrative guidance and write well-supported memoranda.
• Ability to review tax models, identify incorrect assumptions or mechanics, and explain required changes.
• Experience managing outside advisors, budgets, and deliverables.
• Ability to manage multiple concurrent projects and make defensible recommendations amid uncertainty.
• Strong communication and cross-functional collaboration skills with Legal, Accounting, and Treasury.
• Bachelor’s degree or equivalent combination of education, training, and experience.

Preferred Qualifications

• CPA, JD, or LLM in taxation.
• 10–15 years of extensive US international tax experience, including public accounting, law firm, and/or in-house multinational technology experience.
• Post-acquisition integration planning experience, including step plans and modeling.
• Experience with transfer pricing, Pillar Two, FDDEI, partnership tax, and non-US tax rules.
• Experience with cross-border cloud, compute, licensing, infrastructure, data-center, energy, joint-venture, or financing structures.
• Experience supporting IRS examinations of international positions.
• Experience scaling or building an international structure at a high-growth company.
• Experience building or reviewing US international tax models.
• Experience using Claude or similar tools for tax research, modeling, or documentation.
• Experience mentoring or developing tax professionals.

Compensation

• Annual salary: $230,000–$300,000 USD.