Senior Manager of International Tax

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Hagerty is a company built by drivers for drivers. We put our members at the center of everything we do and are dedicated to making it easier and more enjoyable for enthusiasts to drive and celebrate the machines they love. We’re proud to be the world’s largest insurer of collectible and enthusiast vehicles and are home to the Hagerty Drivers Club, the world’s largest car club. Our Marketplace business presents live and digital sales across the U.S. and Europe, we host a number of driving events and concours, and our award-winning automotive journalists produce the most popular car magazine globally, alongside internationally awarded videos. We’re committed to Never Stop Driving. Ready to get in the driver’s seat? Join us!

As Senior Manager – U.S. International Tax, you’ll lead and manage all aspects of U.S. international tax compliance, transfer pricing, and international tax accounting under ASC 740. This role is a key member of the tax leadership team and will serve as a strategic advisor to finance, legal, treasury, and business partners on cross-border tax matters. The position requires deep technical expertise, strong judgment, and the ability to operate effectively in a complex multinational environment, including partnership structures and public company reporting requirements. The role requires someone dedicated to the continuous improvement of existing processes, technology solutions and documentation. The ideal candidate will be a team player with a highly analytical mindset, strong work ethic, extreme attention to detail with a desire to provide quality service to internal and external stakeholders and help build a best in class tax function.

What you’ll do

Global Minimum Tax (BEPS Pillar Two / GLoBE)

• Lead the implementation and ongoing compliance with BEPS Pillar Two (GLoBE) requirements across relevant jurisdictions.
• Oversee calculation of jurisdictional effective tax rates and top-up taxes under GLoBE rules, including income inclusion rule (IIR), undertaxed profits rule (UTPR), and qualified domestic minimum top-up taxes (QDMTT).
• Manage data collection, validation, and reporting processes required for GLoBE compliance, including coordination with finance, IT, and external advisors.
• Evaluate the impact of Pillar Two on the company’s global tax profile, including interaction with U.S. tax rules (e.g., GILTI, FTCs).
• Support development and documentation of accounting positions related to Pillar Two, including ASC 740 implications and required disclosures.
• Monitor global legislative adoption and ensure timely implementation of new country-specific requirements.

International Tax Accounting (ASC 740)

• Lead the international components of the income tax provision, including calculation of GILTI, Subpart F, FTCs, and other cross-border impacts on the effective tax rate.
• Incorporate BEPS Pillar Two impacts into the tax provision, including current and deferred tax considerations, policy elections, and disclosure requirements.
• Analyze and document tax positions related to outside basis differences (including partnership investments), indefinite reinvestment assertions, and valuation allowance considerations.
• Support quarterly and annual reporting, including ETR drivers, return-to-provision adjustments, and tax footnote disclosures.
• Coordinate with external auditors and internal stakeholders to support audit requirements and technical position documentation.
• Evaluate and document uncertain tax positions (ASC 740-10), including those related to international and Pillar Two matters.

U.S. International Tax Compliance

• Lead the preparation and review of U.S. international tax compliance, including Forms 5471, 5472, 8858, 8865, 1118, and related disclosures.
• Oversee calculations related to GILTI, Subpart F income, FDII, BEAT, foreign tax credits (including FTC limitation and carryforwards), and earnings & profits (E&P).
• Manage and review work performed by external advisors to ensure accuracy, completeness, and alignment with internal positions.
• Coordinate with domestic tax and provision teams to ensure consistency between compliance and financial reporting.
• Monitor legislative and regulatory developments (U.S. and OECD), including BEPS initiatives, and assess implications to the company.

Transfer Pricing

• Oversee the design, implementation, and governance of global transfer pricing policies in alignment with business operations and OECD guidelines.
• Manage preparation and review of transfer pricing documentation (Master File, Local Files, Country-by-Country reporting).
• Partner with finance and operations to operationalize intercompany agreements and ensure proper execution of transfer pricing policies.
• Support transfer pricing audits, controversy matters, and advance pricing agreement (APA) processes.
• Monitor intercompany transactions to ensure compliance with arm’s-length standards and alignment with GLoBE outcomes.

Planning & Advisory

• Provide technical support and planning for cross-border transactions, restructurings, and legal entity optimization initiatives, including Pillar Two considerations.
• Assess tax implications of global expansion, including permanent establishment risk, withholding taxes, indirect taxes (VAT/GST), and minimum tax regimes.
• Support M&A transactions, including due diligence, structuring, and post-acquisition integration, including GLoBE modeling and risk assessment.
• Advise on tax-efficient structuring of intercompany financing, cash repatriation strategies, and global effective tax rate optimization.

Process Improvement & Controls

• Strengthen processes, documentation, and internal controls over international tax reporting, including SOX-relevant controls and emerging Pillar Two requirements.
• Partner with tax technology and finance teams to implement and enhance systems supporting GLoBE calculations and reporting.
• Maintain robust documentation supporting key tax positions, judgments, and estimates, including GLoBE assumptions and methodologies.
• Identify opportunities to improve efficiency, scalability, and transparency in global tax operations.

Qualifications

• Bachelor’s degree in Tax, Accounting, Finance, or related field; CPA and/or Master’s in Tax preferred.
• 8+ years of experience in public accounting and/or multinational corporate tax department.
• Strong technical knowledge of U.S. international tax (Subpart F, GILTI, FTC, BEAT, FDII).
• Experience with transfer pricing concepts, intercompany arrangements, and documentation requirements.
• Deep understanding of ASC 740, including international tax provision and uncertain tax positions.
• Familiarity with BEPS Pillar Two (GLoBE) rules or global minimum tax frameworks preferred.
• Experience working with external auditors and managing advisor relationships.
• Strong analytical, communication, and project management skills.

This might describe you

• Experience in a publicly traded company environment.
• Familiarity with partnership taxation and complex legal structures (e.g., Up-C structures, outside basis considerations).
• Experience with tax provision and compliance software (e.g., OneSource, Corptax, or similar).
• Experience supporting or implementing BEPS Pillar Two compliance and reporting processes.
• Exposure to global operations across Europe and other non-U.S. jurisdictions.
• Strategic thinker with strong technical and problem-solving capabilities.
• Ability to translate complex tax concepts (including Pillar Two) into practical business guidance.
• Strong leadership and cross-functional collaboration skills.
• High attention to detail with a focus on accuracy, governance, and control.

Over and above

• CPA preferred but not required.
• Experience with Workday Accounting is an asset.
• Audit defense experience

Other things to note

• This position is open to U.S. remote work. However, team members who reside within 20 miles of the Traverse City headquarters will follow a hybrid schedule, working from the office three days per week.
• Familiarity with public company requirements, including Sarbanes Oxley and key regulations, if applicable. For SOX compliant roles, responsible for designing, executing, and documenting internal controls where they have been identified as owners to prevent errors in financial reporting, processes, and business operations. Including attestation to the completeness, accuracy, and compliance of all financial reporting data, where applicable.

If you reside in the following jurisdictions: Illinois, Colorado, California, District of Columbia, Hawaii, Maryland, Minnesota, Nevada, New York, or Jersey City, New Jersey, Cincinnati or Toledo, Ohio, Rhode Island, Washington, British Columbia, Canada please email recruiting@hagerty.com for compensation, comprehensive benefits and the perks that set us apart. 

At Hagerty, we share the road. We are an inclusive automotive community where all are welcomed, valued and belong regardless of race, gender, age, or car preference.  We are united by our shared passion for driving, our commitment to preserve car culture for future generations and our desire to make a positive impact in the world.

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If you like wild growth and working with happy, enthusiastic over-achievers, you'll enjoy your career with us!