Senior Manager - International Tax & Transaction Services (Financial Services)

About the role

EY is hiring a Senior Manager for its International Tax & Transaction Services advisory practice within the Financial Services group. The role provides international transaction tax services, including tax structuring, tax due diligence and tax modelling, to a broad range of high-profile clients. It is a hybrid position based in Warang (Sydney) or Naarm (Melbourne), and roles can potentially be adjusted to work flexibly with reduced hours.

Key responsibilities

• Advise superannuation funds and other institutional investors on domestic and international investment transactions across infrastructure, real estate, private equity, private credit and alternative asset classes.
• Lead tax structuring, due diligence, tax modelling and documentation review workstreams for inbound and outbound investments, including direct investments, co-investments, fund investments and asset disposals.
• Provide practical advice on the tax implications of global investment structures, including controlled foreign company and foreign hybrid limited partnership issues, access to foreign income tax offsets, access to double tax agreements and hybrid mismatch rules.
• Coordinate domestic and cross-border teams to deliver integrated tax advice on large-scale domestic and offshore transactions.
• Partner with tax compliance teams so that tax considerations are reflected throughout the investment lifecycle.

Required profile

• Extensive experience advising superannuation funds or large institutional investors on investment transactions and international tax matters.
• Demonstrated experience advising on foreign hybrid limited partnership, CFC, FITO and treaty eligibility issues.
• Experience advising on cross-border transactions involving the United States, United Kingdom, Europe and New Zealand.
• Commercially focused, able to explain complex international tax issues, with proven ability to build trusted relationships with clients and domestic and international teams.

Required skills

• Strong understanding of the taxation of offshore investment structures such as Delaware LPs, Luxembourg structures and English Limited Partnerships.
• Transaction execution capability, including tax due diligence, structuring, modelling and negotiation of transaction documentation.
• Ideally: experience advising superannuation funds on offshore capital deployment, US tax issues relevant to superannuation investors (treaty claims, partnership investment and REIT structures), and coordinating global teams for cross-border transactions.

What we offer

• Career development with future-focused skills and world-class experiences.
• Flexible work arrangements.
• A benefits package including a yearly wellness incentive, an extra 8 weeks of flex leave per year, and family-friendly policies including up to 26 weeks of gender-neutral paid parental leave.
• A competitive salary open to negotiation depending on skills and experience.