Reporting directly to the Director, Global Tax Controversy, McDonald’s is looking for a Manager of Global Tax Controversy to manage and coordinate the US federal and international income tax aspects of IRS audits as well as other major foreign tax audits. The Manager of Global Tax Controversy will help manage the day-to-day relationship with the IRS and will contribute to the development of audit strategies. The Manager of Global Tax Controversy will also develop efficiencies in audit timelines/closures; gather and review audit ready documentation; draft responses to various information requests from multiple tax authorities, including the IRS; collaborate with all functions in tax to ensure tax accounting and controversy aspects are appropriately assessed and documented; coordinate with International Tax Operations team to ensure all audit ready documentation is maintained; participate in functional interviews; participate in special projects including assistance with amended US tax return filings as a result of the settlements; and involvement with the US tax aspects relating to global audits, including assistance with claims for Foreign Tax Credits and coordination on US Competent Authority matters.Responsibilities:Manage the day-to-day aspects of US federal and international income tax aspects of IRS audits and other major foreign tax auditsCompile information and respond to Information Document Requests, Notices of Proposed Adjustments, and other exam related mattersResearch various tax matters and draft technical memoranda to support tax return positions relating to IRS Information Document Requests, Notices of Proposed Adjustments, Protests of Proposed Examination Changes, etc.Management of cross-functional teams to effectively build-out timelines for IRS deliverables, and work with teams to ensure timely submission of information to IRSWork with advisors on settlement strategies, appeals process, and final results Oversight of amended US income tax return compliance resulting from the audit adjustments, including tracking of amended returns/protective claim filings and managing cross-functional teams to file timely amended returns. This includes working with our co-sourcing firm, McDonald’s US federal and state income tax teams in addition to working with McDonald’s International Tax Operations team on Foreign Tax Credit carryback and carryforward tracking, as adjusted for potential audit adjustmentsKey advisor in working with Director of Global Tax Controversy to manage ASC 740 aspects of relevant auditsReview IRS interest/penalty calculations for ASC 740 and settlement purposes. In addition to managing the IRS audit, this role occasionally assists with other dispute resolution activities, including coordination on global audits relating to US foreign tax credits claims and involvement with US Competent Authority mattersBenefits eligible: Yes
Bonus eligible: Yes
Long term incentive eligible: Yes
The expected salary range for this role is $112,860 – $143,900 per year
The above represents the expected salary range for this job requisition. Ultimately, in determining your pay, we may also consider your experience, and other job-related factors.