Senior Manager, International Tax Controversy
Core
Senior Manager leading complex U.S. international tax controversy strategies, managing IRS examinations, and resolving tax issues for Eaton's global operations.
Role type
Senior Manager, International Tax Controversy
Builds
Tax resolution strategies and documentation for multinational operations
Domain
U.S. International Tax / Corporate Tax Controversy
Deliverable
client delivery
Required skills
U.S. international tax rules, IRS examination management, tax risk management, foreign tax credits, Subpart F, GILTI, FDII, withholding taxes, tax treaties, permanent establishment, repatriation transactions, financial modeling, data analytics
Preferred skills
CPA, J.D., LL.M. in Taxation, Master's in Taxation, ASC 740 knowledge, Microsoft Excel/Power BI/Copilot proficiency, mentoring junior professionals
Technologies
Microsoft Excel, Word, PowerPoint, SharePoint, Power BI, Copilot
Responsibilities
Develop and execute strategies for IRS examinations and international tax issues; Analyze IRS positions and assess technical/financial implications; Prepare technical analyses and supporting documentation; Coordinate responses to tax authority inquiries; Monitor developments in U.S. international tax law; Model complex multi-year scenarios for strategic decision-making; Mentor junior team members
Seniority
Senior Manager, strategic execution and mentorship
