Senior Tax Manager - International

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Job Description: The Senior Tax Manager - International serves as the dedicated "One Roof" Subject Matter Expert (SME) and functional lead for US international tax compliance, transfer pricing governance, cross-border structuring, and ASC 740 / IAS 12 international tax accounting across Airbus Americas' $8B+ annual gross receipts footprint spanning 26+ legal entities and 3 operating divisions (Commercial Aircraft, Helicopters, and Space & Defense). Reporting directly to the Head of Commercial and Indirect Tax, this role drives the operational harmonization of cross-border tax policies and establishing a centralized, audit-ready functional center of excellence. The position leads technical tax workstreams for regional Mergers, Divestitures & Acquisitions (MD&A), legal entity rationalization, OECD Pillar Two / GloBE implementation, and defends international positions during IRS Large Business & International (LB&I) examinations. The International Senior Tax Manager provides technical leadership and mentorship to Senior Tax Analysts, and acts as the primary business-partnering interface to regional business unit Heads of Finance (HoFs), Treasury, Legal Counsel, and European Headquarters Group Tax Competence Centers to structure compliant intercompany supply chains, Service Level Agreements (SLAs), and cross-border financing.

Primary Responsibilities

Tax Advisory US and International: 25% Deliver strategic and technical tax counsel to European parent entities and US affiliates regarding inbound capitalization, permanent establishment (PE) risk exposure, treaty withholding reductions, and corporate distributions under Sections 385, 267A, and 894. Lead tax advisory topics such as US international tax reform impacts, foreign statutory changes, and OECD initiatives on consolidated cash flows and effective tax rates (ETR), delivering strategic insights to the Head of Commercial Tax. Partner with divisional Heads of Finance (HoFs), Procurement, and Legal Counsel across Commercial Aircraft, Helicopters, and Space & Defense to structure compliant intercompany supply chains, Service Level Agreements (SLAs), management fee allocations, and intellectual property licensing. Joint effort with HR covering global mobility topics, ensuring corporate tax impacts of employee mobility are identified and structured efficiently. Provide audit & notices support for US and foreign entities related to international topics.

Mergers, Divestitures & Acquisitions & Special Projects including OneRoof Initiatives

25% Lead MD&A transactions that will perform due diligence, provide key inputs pre and post-closing and manage communications with internal and outside stakeholders throughout the process. Direct buy-side and sell-side tax due diligence workstreams; evaluate historical target tax liabilities and exposures, review purchase and financing agreements, and negotiate tax indemnity, representation, and covenant provisions. Formulate transaction structures (e.g., Section 338(h)(10)/1060 purchase price allocations, Section 382 attribute preservation, and tax‑deferred corporate reorganizations) to maximize amortizable goodwill, step‑ups in tax basis, and post‑transaction attribute utilization. Anticipate target impacts to US consolidated tax positions (ex. BEAT, GILTI, etc.) and design mitigation strategies, as needed. Drive cross‑divisional restructuring and post‑closing operational integration under the One Roof corporate governance framework; influence regional business unit leaders and legal teams to dismantle redundant legal entities, streamline intercompany financing, and reduce corporate administrative drag.

Transfer Pricing & Controversy

25% Oversee annual documentation of transfer pricing analysis and positions. Collaborate with European colleagues on reciprocal effect, tax adjustments, financial impacts and cash settlements. Monitor transfer pricing results, identify policy or compliance gaps, recommend adjustments, and support the operational execution of transfer pricing models. Manage data collection with internal parties to coordinate with external tax firm analysis and report deliverables. Oversight on operational implementation of bilateral Advance Pricing Agreement (APA) including supporting renewal negotiations between the Internal Revenue Service and French tax authorities, covering $5B–$6B in annual cross‑border transactions. Lead the design, implementation, and ongoing maintenance of regional transfer pricing compliance and strategies aligned with business goals and regulatory requirements. Lead transfer pricing audits, examinations, and controversy matters by preparing analyses, documentation, and responses to tax authority requests. Partner with Finance, Supply Chain, and business teams on tax‑efficient operating models, restructurings, acquisitions, and other strategic initiatives. Develop financial models, profitability analysis, reporting tools, and governance processes while communicating transfer pricing requirements effectively to both technical and non‑technical stakeholders.

US International Tax Compliance & Controversy

25% Direct and review annual US international informational returns and disclosure packages, including Forms 5471, 5472, 8858, 8865. Prepare and review certain entity Forms 1120‑F. Oversee foreign withholding compliance, managing annual Form 1042/1042‑S reporting and reviewing Form W‑8BEN‑E certifications across US operating affiliates. Manage BEPS reporting and data collection across US entities in scope for reporting to the European group tax team, including Country‑by‑Country Reporting (CbCR) and OECD Pillar Two / GloBE data packs. Monitor Section 385 documentation, intercompany interest expense limitation (Section 163(j)), and outbound dividend and debt flows in close coordination with US Treasury and corporate financing teams. Compute and review the international aspects of quarterly and annual income tax provisions in accordance with ASC 740 and IAS 12 for US consolidated entities and standalone inbound reporting entities. Calculate foreign tax credits, Subpart F, GILTI, BEAT, FDII, and foreign withholding tax accruals; assess uncertain tax positions under FIN 48 (ASC 740‑10). Lead IRS or State tax audits, examinations, and controversy on international matters by preparing analyses, documentation, and responses to tax authority requests.

Additional Responsibilities

Other duties as assigned: Champion department digital transformation by designing automated workflows (Alteryx, Power BI) and supporting SAP S/4HANA ERP tax integrations related to international topics. Special projects

Qualified Experience and Training

Education: Required Bachelor’s degree in accounting from an accredited four‑year college or university. Preferred Master of Laws (LL.M.) in Taxation, Juris Doctor (J.D.), or Master of Science