Senior Manager, International Tax Controversy

Senior Manager, International Tax Controversy

Eaton is hiring a Senior Manager, International Tax Controversy in Houston, TX or Cleveland, OH. Relocation assistance is offered.

This role is a key member of Eaton's Tax Controversy team. The Senior Manager, International Tax Controversy partners closely with senior tax leadership to develop and execute strategies for managing complex U.S. international tax matters. The role supports IRS examinations, issue resolution efforts, and other significant tax matters arising from Eaton's global operations. Success in this position requires deep expertise in U.S. international tax rules, tax authority interactions, and tax risk management.

The ideal candidate combines strong technical international tax knowledge with practical experience managing complex tax examinations and resolving issues affecting multinational business operations.

The expected annual salary range for this role is $165000 - $242000 a year. This position is also eligible for a variable incentive program. Please note the salary information shown above is a general guideline only. Salaries are based upon candidate skills, experience, and qualifications, as well as market and business considerations.

What You'll Do:

Collaborate with the tax team to analyze and manage complex U.S. international tax matters arising from Eaton's global operations.

Develop and execute strategies to address IRS examinations and information requests involving international tax issues.

Analyze IRS positions and assess technical, financial, and operational implications.

Prepare technical analyses and supporting documentation related to international tax matters.

Coordinate responses to tax authority inquiries and examination requests.

Support relationships with external advisors and support engagement with tax authorities.

Analyze issues involving foreign tax credits, Subpart F income, GILTI, FDII, withholding taxes, tax treaties, permanent establishment matters, repatriation transactions, and other international tax topics.

Monitor developments in U.S. international tax law and evaluate their potential impact on the company.

Model and analyze complex, multi-year scenarios to support strategic decision-making and risk assessment.

Leverage technology and data analytics tools to improve efficiency, consistency, and visibility across tax controversy processes.

Review work and mentor junior team members while promoting technical excellence across the organization.

Qualifications:

Basic Qualifications:

Bachelor's degree from an accredited institution

Minimum of 10 years of experience in U.S. international tax, tax controversy, tax advisory, or tax compliance

Experience managing complex U.S. international tax matters for multinational enterprises

Authorized to work in the United States without current or future sponsorship

Preferred Qualifications:

Bachelor's degree from an accredited institution in Accounting, Finance, Tax, or a related field

CPA, Juris Doctor (J.D.), LL.M. in Taxation, or Master's degree in Taxation

Significant experience with U.S. international tax matters within a multinational corporation, public accounting firm, advisory practice, or government agency

Experience managing IRS examinations, information document requests, and issue resolution involving international tax matters

Strong technical knowledge of U.S. international tax provisions, including foreign tax credits, Subpart F, GILTI, FDII, withholding taxes, tax treaties, and permanent establishment matters

Strong research, analytical, problem-solving, and project management skills

Experience reviewing work and mentoring junior professionals

Advanced proficiency in Microsoft Excel, Word, and PowerPoint, including data analysis and financial modeling

Experience with SharePoint, Power BI, Copilot, and other Microsoft collaboration and AI tools

Strong understanding of the interaction between tax, accounting, treasury, legal, and business functions in a multinational organization

Knowledge of ASC 740 and the financial reporting implications of international tax matters

Ability to analyze complex transactions and determine appropriate tax treatment

Proficiency with standard business software and the ability to learn and navigate internal reporting, forecasting, and tax technology systems