Senior Tax Manager - International (US International Tax)

Location: Herndon Area, VA, United States. Full-time position; 10% domestic and international travel. US citizenship and current US work authorization are required. hirify.global does not sponsor visas for US positions unless specified.

Salary: $160,000–$180,000 per year, depending on experience and geographic differential.

Company

hirify.global Defence and Space is part of hirify.global, an aerospace and defense corporation operating across Commercial Aircraft, Helicopters, and Space & Defense divisions.

What you will do

• Lead US international tax compliance, transfer pricing governance, cross-border structuring, and ASC 740 / IAS 12 international tax accounting across 26+ legal entities and three operating divisions.
• Provide technical tax advice on inbound capitalization, permanent establishment risk, treaty withholding, corporate distributions, US international tax reform, foreign statutory changes, and OECD initiatives.
• Lead M&A tax due diligence, transaction structuring, purchase price allocations, tax indemnities, legal entity rationalization, restructuring, and post-closing integration.
• Oversee transfer pricing documentation, bilateral APA implementation and renewal, operational transfer pricing models, audits, examinations, and controversy matters.
• Direct US international informational returns, Forms 1120-F, foreign withholding reporting, BEPS/CbCR and Pillar Two/GloBE data collection, tax provisions, foreign tax credits, Subpart F, GILTI, BEAT, FDII, and uncertain tax positions.
• Mentor Senior Tax Analysts and partner with Finance, Treasury, Legal, Procurement, Supply Chain, HR, business unit finance leaders, European tax teams, and external advisers; support Alteryx, Power BI, and SAP S/4HANA tax transformation initiatives.

Requirements

• Bachelor’s degree in accounting from an accredited four-year college or university.
• 10–12+ years of diverse tax experience, including at least 5 years in a public accounting tax department or large multinational corporation focused on corporate income tax.
• US citizenship and current US work authorization.
• In-depth technical mastery of US inbound and outbound corporate taxation, including Sections 163(j), 267A, 385, 482, 59A/BEAT, 250/FDII, Subpart F, and foreign tax credits.
• Comprehensive understanding of OECD Transfer Pricing Guidelines, BEPS action items, and Pillar Two/GloBE readiness frameworks.
• Knowledge of consolidated return regulations, combined/consolidated/unitary state filings, ASC 740 disclosures, FIN 48, Subchapter C, corporate distributions, adjustments, and inbound informational reporting.
• Proven capability in M&A tax due diligence, Section 338/1060 purchase price allocations, legal entity rationalization, and cross-border restructuring.
• Self-directed project management ability in a fast-paced, multi-entity environment; strong tax research skills using CCH or equivalent platforms.
• English proficiency, including the ability to work with legal documents.

Nice to have

• 4–5 years dedicated to US international tax compliance, transfer pricing, or cross-border structuring in a Big 4 firm, large multinational corporate tax department, or combination thereof.
• Experience with inbound companies, aerospace, or manufacturing.
• Master of Laws in Taxation, Juris Doctor, Master of Science in Taxation, CPA licensure, or equivalent preferred credentials.
• Experience with Corptax and SAP S/4HANA.

Culture & Benefits

• Direct-hire employment with hirify.global.
• Equal employment opportunity and reasonable accommodations for applicants with disabilities.
• Integrity, compliance awareness, workforce diversity, and an inclusive working environment are emphasized.
• Employment is at will and does not provide guaranteed or tenured employment.