Senior US International Tax Counsel

Based in New York City, the Senior US International Tax Counsel is responsible for all US and international tax matters of a US holding company owning a portfolio of subsidiaries and investments located in the United States and in multiple foreign jurisdictions. The role covers tax structuring, cross-border transactions, cash repatriation, group reorganizations, and strategic tax planning at the holding and sub-holding levels, while serving as a key advisor to senior management and relevant stakeholders.

The Senior US International Tax Counsel is responsible for the full US tax compliance of the US holding company, including federal, state, and related information filings, whether handled internally or through external advisors. The position does not include day-to-day responsibility for US tax compliance of US-based operating entities, which remains with those entities and/or their dedicated external providers; instead, the role ensures consistency between local compliance, group tax positions, and the holding company’s broader tax strategy.

The role also serves as a primary tax liaison with the French and US shareholders of the holding company, providing clear guidance on tax implications of distributions, restructurings, financing arrangements, governance decisions, and changes in the ownership chain. 

• Advise the US holding company on US federal, state, and international tax matters affecting the group structure and investment platform.
• Lead tax analysis for cross-border transactions, including acquisitions, disposals, internal reorganizations, refinancing, recapitalizations, and legal entity simplification projects.
• Manage US international tax matters affecting non-US subsidiaries and investments, including CFC, Subpart F, GILTI, foreign tax credit, withholding tax, treaty, and related cross-border issues.
• Design and implement tax-efficient cash repatriation and intra-group funding strategies, including dividends, distributions, intercompany loans, and other upstream payment mechanisms.
• Oversee and coordinate the full US tax compliance of the US holding company, including federal and state income tax returns, information returns, tax elections, estimated tax payments, extensions, and related filings.
• Review work prepared by outside tax advisors for the US holding company and ensure filings are accurate, timely, technically supportable, and aligned with the group’s documented tax positions.
• Maintain oversight of the tax implications of holding-level transactions and ensure that legal, treasury, accounting, and shareholder actions are implemented in a tax-efficient and well-documented manner.
• Monitor developments in US and international tax law, administrative guidance, and enforcement trends, and assess their impact on the holding company and its portfolio structure.
• Coordinate external advisors in the United States and abroad, define scope, challenge recommendations where appropriate, and manage budgets and delivery standards.
• Support M&A and investment activity through tax due diligence, structuring analysis, acquisition financing review, and post-acquisition integration planning.
• Prepare technical memoranda, executive summaries, internal policies, and board- or shareholder-level briefing materials on material tax matters.
• Assist in tax audits, controversy matters, and responses to tax authority inquiries involving the US holding company and, where relevant, group-wide structural issues.

SCOPE AND SHAREHOLDER LIAISON:

• The Senior US International Tax Counsel maintains a consolidated view of the group’s tax profile and risks but does not assume day-to-day responsibility for the US tax compliance of US operating companies within the portfolio. That operational compliance remains at the level of each operating entity and/or its appointed internal finance team or outside advisors.
• At the same time, the role ensures that local compliance outcomes remain consistent with the holding company’s tax structure, intercompany arrangements, reporting positions, and broader strategic objectives. 
• The position also acts as a central tax interface between the holding company, its operating subsidiaries, and the French and US shareholders on matters such as distributions, ownership restructuring, financing flows, and significant tax exposures.

SKILLS:

• CPA (or equivalent) and/or a tax-focused master's (MST/LLM in Tax) preferred.
• Approximately 10 years of relevant experience in US corporate and international tax, ideally gained in a leading law firm, Big Four firm, and/or the in-house tax function of a multinational or investment-driven group.
• Strong command of US corporate tax, US international tax, and cross-border structuring principles, including experience with complex multi-jurisdiction holding structures.
• Proven experience managing holding-company tax compliance and coordinating external tax advisors for US federal and state filings.
• Demonstrated ability to translate technical tax issues into clear, practical recommendations for senior management, legal teams, finance teams, and shareholders.
• Strong drafting, judgment, project management, and stakeholder management skills.
• Fluency in English is required; French is a plus given the need to interact with French shareholders and cross-border stakeholders.