Manager, M&A Tax

The position requires someone with a strong technical U.S. federal tax Subchapter C background. Experience with reorganization tax code provision and consolidated return regulations is a plus. The candidate should have at least 4 years of combined U.S.M&A tax and federal tax experience with either a large public accounting firm and/or a large MNC. The position’s salary and title will be commensurate with the individual’s experience.

Position Summary:

1. Assist with M&A due diligence, including the review of target company financial and tax return data.

2. Scenario planning related to competing acquisition alternatives and internal restructuring options.

3. Perform IRC section 382 analysis on acquired loss companies, including the computation of the Section 382 limitation amount.

4. Analyze, and perform necessary calculations, to quantify the difference between acquiring the assets or stock of an acquisition target.

5. Calculate the inside and outside basis of company-owned subsidiaries and partnerships for internal taxable and nontaxable reorganizations or other tax planning purposes.

6. Consult with business unit and/or legal personnel for external acquisition and internal reorganizations.

7. Perform due diligence, including related computational support, in the context of IRC section 332 and tax-free liquidations.

8. Perform due diligence, including related computational support, related to IRC section 351 and tax-free contributions.

9. Determine the necessary income tax disclosures related to closed transactions.

10. Implement projects and drive them through to a timely, successful conclusion.

11. Assist with the review of federal tax returns.

12. Participate in other special projects as assigned by senior departmental management.

13. Assist with tax research and provide written memorandum summarizing the conclusions of said research.

Successful Candidate Will Possess a Combination of the following Personal Characteristics:

1. Comfortable with lateral and higher contact with staff and senior managers in other corporate departments and with business unit personnel.

2. Not afraid to “roll up the sleeves” while being able to retain big picture thinking.

3. Willing to get involved in ad hoc planning projects and manage the tax issues associated with those projects either by direct action or through external advisers.

4. Desire to work in a flexible “team-based” environment.

5. Ability to juggle concurrent projects and smoothly move from project to project with little advance notice.

6. Thriving in an environment where you must “roll up the sleeves” and get involved in the details while also retaining big picture thinking.

7. Significant experience with Excel.

Education:

B.S. or similar degree in Accounting; Masters in tax is a plus. C.P.A. is a plus. J.D. is a plus.