Vice President of Tax Planning and M&A

Our client, a very large publicly traded company in Los Angeles, has engaged us to bring them a Vice President of Tax.  This senior-level international and transactional tax executive and/or attorney will manage tax planning issues.  This is an exciting tax position in a highly dynamic company with an extremely effective tax department.  We are seeking someone to work side-by-side with Management, Corporate Development, Legal, Finance and Operations to accomplish the company’s objectives. Join a talented tax group that is completely engaged in business decisions and is viewed as a high-impact profit center instead of overhead.

Below you’ll find more details about the opportunity. We hope it brings to mind someone who may be interested in this highly visible position, and we invite you to share the information with others.

Responsibilities
International Tax

• • Review, draft and negotiate tax-related provisions in third party licenses, services, and financing agreements
  • Oversee planning and management of the OECD Pillar Two and Country-by-Country Reporting frameworks, including support for compliance processes, safe harbor analyses, and related reporting
  • Advise on the structuring of foreign activities
  • Advise on the tax aspects of third-party financing arrangements
  • Address the international tax issues of a Canadian multinational company that has offices in Canada, the US, Europe, Asia and Australia
  • Review and update intercompany agreements and related transfer pricing documentation
  • Support legal entity reorganization and rationalization
  • Assist with quarterly and year-end tax provision memos and documentation
  • Assist with foreign tax examinations, including strategic guidance and documentation
  • Advise and support global treasury cash management functions, including intercompany settlements
  • Manage and review US and Canadian international tax forms and related filings, including coordination with M&A tax reporting requirements
  • Identify opportunities to optimize the company’s tax position, including with respect to Section 163(j) limitation, Base Erosion and Anti-Abuse Tax (BEAT), and Canadian foreign accrual property income (FAPI) rules
  • Manage external advisors and collaborate with internal stakeholders

Restructuring, Mergers & Acquisitions

• • Assist with the tax structuring and execution of domestic and cross-border M&A transactions, including joint ventures, acquisitions, and divestitures
  • Perform tax due diligence and communicate key findings to senior management in a concise manner
  • Review and draft tax-related contractual provisions in acquisition documents (LOI, SPA, disclosure schedules, etc.)
  • Negotiate tax deal points with sellers/buyers
  • Provide tax support to the financial deal model
  • Acquisition/disposition structure design, including internal financing arrangements when appropriate
  • Provide comprehensive tax support to post-acquisition integration workstream, including all tax-related aspects involving post-acquisition legal entity structure, IP ownership, functional deployment and intercompany transaction flows

Qualifications and Skills

• 10+ years progressive experience (preferably obtained in both a corporate tax department and with the tax department of a Big 4 accounting firm or international law firm)
• Strong expertise in US domestic and international taxation, including Subchapter C, Subchapter K, transfer pricing, withholding tax, US tax treaties and partnership compliance, including familiarity with the financial statement impact of tax matters
• Working knowledge of and experience with OECD Pillar Two rules, country-by-country reporting requirements, and related global minimum tax frameworks
• Experience managing domestic and foreign tax matters, including corporate taxation, partnership taxation, accounting methods, tax treaties, permanent establishment and VAT (planning, compliance and disputes), and withholding taxes
• Extensive experience leading M&A transactions, specializing in Subchapter C, partnership taxation, and post-acquisition integration
• Significant experience advising on the tax implications of financing transactions and capital structures in a multinational context
• Proven ability to lead tax support of corporate initiatives from inception, planning, approval, execution, and review by external auditors and tax authorities
• Proven ability to build strong cross-functional relationships, including across tax, legal, controllership, treasury, HR, and the company’s business lines
• Strong communication skills, with proven ability to distill complex tax concepts into clear, actionable guidance for non-tax stakeholders, including executive leadership, to support well-informed decision-making

Great if you also Have

• Extensive experience in modelling, understanding and communicating to senior management the financial impacts of tax planning
• Strong PowerPoint skills, with the ability to clearly illustrate and communicate complex, multi-step transactions and processes
• Undergraduate degree in economics, accounting or finance
• CPA, MS Tax, JD, and/or LLM (Tax) with expertise in partnership taxation
• Contract drafting on tax matters involving IP production and licensing arrangements
• Proven ability to build effective and efficient working relationships with external advisors and business partners
• Experience managing the transfer pricing aspects of IP, distribution, and financing businesses