Senior International Tax Controversy Manager (Relocation)

Eaton; Houston (TX); On-site; USD 165,000 - 242,000; Full time

Job summary

Eaton, based in Houston, TX (also in Cleveland, OH), is hiring a Senior Manager, International Tax Controversy. This role partners with tax leadership to manage U.S. international tax matters, IRS examinations, and issue resolution for Eaton’s global operations.

Relocation assistance is offered. The ideal candidate has deep expertise in U.S. international tax rules and tax risk management, with experience guiding complex examinations and cross-functional teams.

Qualifications

• Bachelor's degree from an accredited institution.
• Minimum of 10 years of experience in U.S. international tax, tax controversy, tax advisory, or tax compliance.
• Experience managing complex U.S. international tax matters for multinational enterprises.
• Authorized to work in the United States without current or future sponsorship.

Responsibilities

• Collaborate with the tax team to manage complex U.S. international tax matters arising from Eaton's global operations.
• Develop and execute strategies to address IRS examinations and information requests involving international tax issues.
• Analyze IRS positions and assess technical, financial, and operational implications.
• Prepare technical analyses and supporting documentation related to international tax matters.
• Coordinate responses to tax authority inquiries and examination requests.
• Support relationships with external advisors and engagement with tax authorities.
• Analyze issues involving foreign tax credits, Subpart F, GILTI, FDII, withholding taxes, tax treaties, permanent establishment matters, repatriation transactions, and other international tax topics.
• Monitor developments in U.S. international tax law and evaluate their potential impact on the company.
• Model and analyze complex, multi-year scenarios to support strategic decision-making and risk assessment.
• Leverage technology and data analytics tools to improve efficiency, consistency, and visibility across tax controversy processes.
• Review work and mentor junior team members while promoting technical excellence across the organization.

Skills

Tax controversy

IRS examinations

Financial modeling

Project management

Data analytics

Education

Bachelor's degree

CPA or JD or LL.M. in Taxation

Tools

Excel

Power BI

SharePoint

Copilot

PowerPoint

Job description

Eaton, based in Houston, TX (also in Cleveland, OH), is hiring a Senior Manager, International Tax Controversy. This role partners with tax leadership to manage U.S. international tax matters, IRS examinations, and issue resolution for Eaton’s global operations.

Relocation assistance is offered. The ideal candidate has deep expertise in U.S. international tax rules and tax risk management, with experience guiding complex examinations and cross-functional teams.