International Tax Manager

The position is primarily responsible for the US international tax compliance obligations of the foreign subsidiaries held under the US (approximately 25) as well as foreign affiliated companies with transactions within the North American region.  The role will also assist in navigating US international tax issues that arise during the annual tax provision and ad hoc consulting engagements as well as coordinate non-US tax issues.  The ideal candidate will have exposure in both tax compliance and planning roles, comfortable processing tax returns in the OneSource Platform by Thompson Reuters, and able to analyze/summarize tax and transaction attribute data with excel.  This role supports the international tax director along with a 2nd US International Tax manager and Transfer Pricing Senior manager.

Responsibilities include:

Compliance

• Co-lead in the full lifecycle of Freudenberg’s US international tax compliance process from initial data collection stages, through workpaper preparation, issue identification, analysis, and resolution, to final return filing/documentation
• Maintain and improve methodologies and tracking tools to quantify and manage US international tax attributes including excess foreign tax credits, foreign source income, CFC basis, E&P, tax pools, etc.
• Prepare or oversee preparation of the following forms:
  • Form 899x series and related GILTI, FDII, BEAT, and 163(j) calculations
  • Form 5471 CFC Reporting and related E&P calculations for 25 subsidiaries
  • Form 1118 and related FTC calculations including foreign source income and expense allocations
  • Protective Form 1120F for certain foreign entities of affiliates with limited US activities
  • Form 1042s Non-Resident Alien Payment and Withholding Reporting and related W-8 documentation and FATCA inquiries as needed
  • Form 5472 and related intercompany transactions reporting
• Maintain and improve methodologies and tracking tools to quantify and manage US international tax attributes including excess foreign tax credits, foreign source income, CFC basis, E&P, tax pools, etc.
• Provide assistance with the US international tax calculations for the annual IFRS tax provision as well as assist and coordinate the local provisions of select foreign entities
• Support with international tax aspects of IRS and certain foreign country tax audits including research and drafting responses to notices

Planning

• Support the International Tax Director on cross-border special tax projects and work cross-functionally with Legal, Treasury, Accounting and HR to provide a wholistic recommendation.  Consult with business groups and senior management on variety of international tax topics.
• Analyze and summarize the US international tax implications of cross-border transactions related to the US, Mexico, and Canada, including dividends, interest, royalties, and business transfers. 
• Assist the business with general withholding tax analysis, permanent establishment questions and treaty review
• Monitor and analyze newly enacted US tax legislation, regulations, and form changes and provide support to ensure adequate processes are in place to comply
• Other duties may be assigned that pertain to the classification.  Demonstrated job duties and knowledge listed are sum for the job classification.  Knowledge of all duties is to be cross functional but specific duties are assigned within available personnel.

Qualifications

• Bachelor's degree or higher in accounting or finance
• 4 years’ experience of Big 4 (or similar) or 8 years’ experience inhouse with a multi-national company with a focus in the international tax space
• CPA or master's degree in taxation (strongly preferred)
• Experience preparing and reviewing US international tax returns
• Supervisor level and project management experience with US international tax filings
• Experience and proven practical knowledge in OneSource Platform including Income Tax, Dataflow, International TAS, and Workpapers Import
•  Experience with Hyperion Financial Management (HFM) favorable
• Tax research experience using BNA/RIA or similar service