US and International Tax Manager in London

At Herbert Smith Freehills Kramer, our ambition is to help you achieve your goals. Exceptional client service and the pursuit of excellence are at our core. We invest in and care about our client relationships, which is why many are incredibly longstanding. We enjoy breaking new ground, as we have for over 100 years.

We are where you need us to be. We are in the world's largest markets, key financial centres and major growth hubs. Our international footprint is extensive and committed. We are at our best tackling complexity and navigating change. We work alongside you on demanding contentious matters, exacting regulatory work and complex public and private market transactions. We are recognised as leading in these areas.

We are immersed in the sectors and challenges that impact you. We are recognised as standing apart in energy, ESG, infrastructure and resources. We’re focused on areas of growth that affect every business across the world, including technology and digitalisation. All of this is achieved by supporting the growth of our people, who help us deliver on our ambition - which is to help you achieve yours.

The Opportunity

Primary Responsibilities:

• US tax matters: Ensuring the accurate and timely submission of all US entity tax returns, K-1s, and other US tax computations and returns.
• Responsibility for the firm’s financial hygiene in respect of tax liabilities by ensuring tax payments are made as appropriate, accurate tax provisions are calculated and maintained, double tax relief claims are maximised, and by monitoring tax balances in statutory accounts.
• Responsibility for state tax and PTET analysis, compliance and payments for non-US entities and partners.
• Ongoing oversight, monitoring and reconciliation of US tax reserves for partners in Australia and non-US tax reserves for partners in the US, taking account of US profit fluctuations throughout the year.
• Analysis and calculation of quarterly US tax prepayments due on behalf of non-US partners.
• Provision of support to US partners to assist them in managing their US tax affairs.
• US Guaranteed Payments – calculations, reconciliations, documentation and general oversight.
• Having oversight of the various administrative US tax processes, such as ITIN applications, information requests to partners, collating signatures for various IRS forms, etc.
• Working with the Tax Reporting, Processes and Controls team to ensure accurate profit allocations to partners worldwide for US tax and reporting purposes, and to different year ends.
• Other international tax matters: Ensuring the efficient completion, on a timely and accurate basis, of all of the firm’s global tax compliance obligations, including income and corporation tax computations and returns.
• Supporting the Director of Tax and Partner Finance and the Head of International Tax with the implementation and management of strategic projects and initiatives including updating and maintaining the firm’s global transfer pricing documentation, new office openings, associations with local law firms, lateral hires, changes to remuneration systems etc.
• Supporting management with specific international tax matters, eg foreign exchange impacts, relocations, partnership entities, responses to tax enquiries, including liaison with tax authorities globally where appropriate.
• Establishing and maintaining systems to monitor legislative changes in tax and reporting requirements (eg transfer pricing, BEPS), and implementing the firm’s policies and reporting in response to these, to ensure compliance in line with legal and regulatory requirements, and the firm’s tax strategy.
• Liaising with colleagues from a non-tax background, both within the finance team and the wider business, to ensure tax is properly understood and factored into decision making across the business.
• Working with the Head of Partner Finance, Tax Processes and Controls to ensure appropriate internal controls and supervision routines are in place for the international tax team’s work.
• Responsibility for other compliance and financial issues, including: Annual Country by Country Report submission, notifications and maintenance and submission of Master and Local Files; Pillar 2 data collection and analysis, reports and notifications; Intercompany recharges; Assisting the Head of International Tax in managing Permanent Establishment risk, and calculating annual profit arising to Permanent Establishments in relevant jurisdictions; Managing withholding tax issues, including provision of appropriate documentation where necessary and collecting certificates of tax deducted, refunds, etc; Managing audits and other activity in respect of an ongoing tax dispute in India; Managing the annual budget process for the Tax & Partner Finance team and tracking external adviser fees against budget.
• Reporting line management of junior members of the team, ensuring continual improvement, appropriate development of talent and succession planning.
• Proactive contribution to the people development initiatives of the Tax & Partner Finance team, such as Academy courses and team morale and wellness initiatives.
• Developing and maintaining strong relationships with Business Finance and management stakeholders across the firm, in particular to pro-actively identify areas of activity where international tax issues may arise, or where the Tax & Partner Finance team should become more significantly involved.
• Working with the Head of Partner Finance, Tax Processes and Controls to evaluate best practice and identify and drive operational improvements in Tax & Partner Finance team processes.
• Ensuring pro-active communication within the Tax & Partner Finance team.

Qualifications, skills and experience

• Proven post-qualification international tax experience in a partnership setting.
• US tax experience a must.
• Over five years' experience in a role in a large organisation where you have operated at a senior advisory or similar level.
• Strong tax technical knowledge across all aspects of international tax especially with regards to the UK and Australia, and a selection of other territories relevant to the firm.
• Strong appreciation of how tax fits into the wider business context from a compliance, commercial and risk perspectives.
• Excellent managerial skills, especially with regard to a specialist team spread across different locations and time zones.
• Demonstration of influencing skills with senior management, especially regarding topics of sensitivity such as tax and remuneration.
• Managing change within their area of responsibility.
• Attention to detail with a high level of accuracy.
• Excellent written and oral communication skills.
• Strong organisational skills and ability to prioritise.
• Educated to degree level or equivalent.
• Qualified accountant and/or tax adviser.

Competencies

• Personal Leadership: Energises those around them, simplifies complexity and makes quality decisions.
• Brings perspective and a constructive approach to high pressure situations and directs attention to solutions.
• Makes sound commercial decisions based on a clear understanding of the business.
• Acts decisively even on the basis of incomplete information.

• Builds Authentic Relationships: Builds highly engaged teams that are diverse and inclusive and can excel in a range of situations.
• Creates an environment that encourages personal accountability, and builds the confidence of others by highlighting their strengths and achievements.

• Collaborates with others: Develops innovative solutions by valuing diversity of thought, expertise and experience.
• Brings a positive energy to the way they work and inspires this in others.
• Draws on internal networks to bring people with the right skills and expertise together to develop solutions.

• Enhances the Client Experience: Always acts with the firm’s clients in mind.
• Prioritises initiatives that will positively impact the client experience and their business.
• Develops solutions that balance client needs and the sustainable profitability of the firm.
• Takes active steps to cultivate and maintain an excellent reputation in the market.

• Achieves Results: Makes things happen in a complex environment.
• Remains focused on long term objectives and broad firm issues.

Team: Business Finance

Working Pattern: Full time

Location: London

Contract type: Permanent Contract

Diversity & Inclusion: We are committed to attracting people from all backgrounds and creating a respectful and inclusive culture where everyone thrives. We see this as essential to our success, including our ability to innovate and achieve sustained high performance. This is a key part of our Values—Human, Bold, and Outstanding.