International Tax Manager/Director

The international tax manager provides direction and management for the international income tax function of Berkshire Hathaway Energy and its subsidiaries to ensure accurate and timely reporting of all income, credits and other items related to foreign operations for all federal, state and local income tax, withholding tax, and information returns. 

The international tax manager also ensures: 

• Accurate and timely reporting of foreign, provincial and other local income, withholding and non-income tax returns

• Responsibility for all U.S. and foreign tax related computations and disclosures in the monthly, quarterly and annual financial statements

• Manage U.S. tax issues related to foreign operations and foreign jurisdiction tax issues, 

• Assist with merger and acquisition activity that involve foreign jurisdictions

• Assist with the training and mentoring of international tax staff

Provide timely and accurate support to the Director of International Tax and Tax Planning to ensure compliance with U.S. and foreign tax law and management of the international tax function for Berkshire Hathaway Energy and its subsidiaries, including:

• Manage income and non-income tax compliance across all jurisdictions in which Berkshire Hathaway Energy operates, including the preparation and review of U.S. federal consolidated and sub-consolidated return reporting for foreign operations, earnings and profits calculations, foreign-source income and foreign tax credit computations, and related international information returns, including Forms 5471, 8865, and 8858

• Manage the U.S. reporting, record keeping and withholding tax requirements with respect to all payments to all foreign persons and entities by any domestic entity owned directly or indirectly by Berkshire Hathaway Energy. Ensure compliance with the Foreign Tax Compliance Act (FATCA). Assist with the preparation and review of all related information and withholding tax returns including Forms 1042 and 1042-S

• Support the preparation of monthly, quarterly and annual income tax provision computations and disclosures related to U.S. and foreign taxation of income from foreign operations

• Assist with the review of Canadian and provincial corporate and partnership income tax returns

• Oversee the preparation of all quarterly estimated tax computations of taxable foreign source income for purposes of U.S. federal quarterly estimated tax payments. 

• Support the development of transfer pricing documentation for all cross-border transactions in all jurisdictions to ensure timely compliance requirements are met in all jurisdictions

• Monitor the Organization for Economic Cooperation and Development (“OECD”) base erosion and profit shifting (“BEPS”) project and ensure accurate and timely compliance with all related legislation and expanded reporting requirements

• Assist with overseeing U.S. employee foreign travels and abroad business activities in foreign jurisdictions to support compliance with foreign payroll withholding, tax return, and related filing requirement

• Provide support related to worldwide tax planning, budgeting and forecasting activities. 

• Monitor, model, document and communicate the impact of U.S. international and foreign tax legislation as it relates to the business activities of Berkshire Hathaway Energy Company and subsidiaries

• Assist with all U.S. and foreign audit requests

• Support merger and acquisition activity in foreign jurisdictions

• Research and analyze complex tax issues

• Draft memoranda regarding tax issues and transactions

• Provide technical leadership and mentoring to international tax staff

• Perform additional responsibilities as requested or assigned

This is a multi-level posting. Candidates may be considered for any of the posted levels, depending on their level of experience and depth of expertise.

• Bachelor's degree in accounting and either a graduate degree, certified public accountant designation, or a law degree with an LLM preferred

• Requires at least 10 years of related experience, including five years in international tax, with strong expertise in international and federal income tax compliance and planning for the International Tax Manager position

• Requires at least 12 years of related experience, including five years in international tax, with strong expertise in international and federal income tax compliance and planning for the International Tax Director position

• Strong leadership and mentoring skills

• Experience with mergers and acquisition and consolidated returns 

• Extensive knowledge of foreign and U.S. federal tax laws, regulatory and tax accounting with the ability to communicate complex concepts clearly

• Strong computer skills including working knowledge of tax systems and research methodologies 

• Effective written, oral and presentation skills 

• Strong interpersonal and leadership skills

• Analytical, problem-solving and decision-making capabilities

• Project management skills with the ability to prioritize and manage multiple tasks projects concurrently

• Affiliation with national, state and industry tax associations