US Tax Manager (Advisory)

About the Job

The Role

We are looking for a US Tax Manager to lead our US tax work. This is an advisory role first. We want someone who can identify the issue, research it, write the memo, explain the answer to a client's CFO, and stand behind the recommendation, while also overseeing the compliance that follows from it. You will work closely with the partners, our transfer pricing and transactions teams, and clients in the US.

Who Will You Report To

Partner, Corporate & International Tax

What You Will Do

Advisory

• Advising Indian groups on US expansion, including choice of entity, check-the-box elections, capitalization and financing, effectively connected income exposure, and profit repatriation.
• Advising US groups with Indian / overseas operations (other jurisdictions) on Subpart F, GILTI (NCTI), FDII (FDDEI), foreign tax credits and BEAT, including the effect of the One Big Beautiful Bill Act changes on existing structures.
• Applying the India–US tax treaty and other tax treaties that US has with various countries to live fact patterns, including permanent establishment, withholding rates, limitation on benefits and treaty-based return positions.
• Supporting cross-border acquisitions, restructurings, flips and reverse flips with tax due diligence and structuring advice, working with our transactions team.
• Working with our transfer pricing team on intercompany arrangements and their effect on US tax positions.
• Advising US-resident individuals and families on Indian assets and income, including foreign information reporting, PFIC exposure and cross-border estate and gift planning.

Compliance and Review

• Reviewing corporate, partnership and individual returns with international content, including Forms 1120, 1120-F, 1065, 1040, 5471, 5472, 8858, 8865, 8621, 1116, 1118, 8938, 3520, 3520-A and FBAR.
• Reviewing withholding compliance, including Forms 1042 and 1042-S and FIRPTA.
• Supporting clients through IRS notices and examinations.

Engagement Leadership

• Running engagements day to day, including scoping, timelines, deadline tracking, budgets and client communication across time zones.
• Reviewing the work of the team and building a US tax bench through training and coaching.
• Keeping clean engagement files, including engagement letters, contemporaneous documentation, taxpayer consents and data-security procedures for US taxpayer information.

Practice Building

• Contributing to proposals, client presentations, articles and webinars on US and cross-border tax.
• Building relationships with US accounting firms, law firms and other referral sources.

What You Bring

• 4 to 6 years of US tax experience, of which at least 2 years in international tax, gained in a Big 4 or national firm, a US tax practice in India, or a tax advisory firm.
• A US CPA license or Enrolled Agent status. Candidates who are Chartered Accountants with the relevant US tax experience and are pursuing the CPA or EA will also be considered.
• A track record of advisory work, not only compliance: research memos you have written, structuring recommendations you have made, and client conversations you have led.
• Strong research skills using primary sources and standard US tax research platforms.
• Clear writing and the ability to turn technical analysis into a recommendation a client can act on.
• Willingness to work some hours overlapping with the US business day.

An advantage, not a requirement: knowledge of Indian direct tax, FEMA or transfer pricing, and experience with India-connected clients.