VP, Tax

Lionsgate is seeking a senior-level international and transactional tax executive and/or attorney to manage tax planning issues for a multinational film, television, and network business. This is an exciting tax planning position in a highly dynamic entertainment company with an extremely effective tax department, working side-by-side with Management, Corporate Development, Legal, Finance and Operations to accomplish the company’s objectives. Join a talented tax group that is completely engaged in business decisions and is viewed as a high-impact profit center instead of overhead.

• International Tax
  • Address the international tax issues of a Canadian multinational company that has offices in Canada, the US, Europe, Asia and Australia
  • Review, draft and negotiate tax-related provisions in third party licenses, services, and financing agreements
  • Oversee planning and management of the OECD Pillar Two and Country-by-Country Reporting frameworks, including support for compliance processes, safe harbor analyses, and related reporting
  • Advise on the structuring of foreign production activities
  • Advise on the tax aspects of third-party financing arrangements
  • Review and update intercompany agreements and related transfer pricing documentation
  • Support legal entity reorganization and rationalization
  • Assist with quarterly and year-end tax provision memos and documentation
  • Assist with foreign tax examinations, including strategic guidance and documentation
  • Advise and support global treasury cash management functions, including intercompany settlements
  • Manage and review US and Canadian international tax forms and related filings, including coordination with M&A tax reporting requirements
  • Identify opportunities to optimize the company’s tax position, including with respect to Section 163(j) limitation, Base Erosion and Anti-Abuse Tax (BEAT), and Canadian foreign accrual property income (FAPI) rules
  • Manage external advisors and collaborate with internal stakeholders
• Restructuring, Mergers & Acquisitions
  • Assist with the tax structuring and execution of domestic and cross-border M&A transactions, including joint ventures, acquisitions, and divestitures
  • Perform tax due diligence and communicate key findings to senior management in a concise manner
  • Review and draft tax-related contractual provisions in acquisition documents (LOI, SPA, disclosure schedules, etc.)
  • Negotiate tax deal points with sellers/buyers
  • Provide tax support to the financial deal model
  • Acquisition/disposition structure design, including internal financing arrangements when appropriate
  • Provide comprehensive tax support to post-acquisition integration workstream, including all tax-related aspects involving post-acquisition legal entity structure, IP ownership, functional deployment and intercompany transaction flows

• 10+ years progressive experience (preferably obtained in both the entertainment industry and with the tax department of a Big 4 accounting or international law firm)
• Strong expertise in US domestic and international taxation, including Subchapter C, Subchapter K, transfer pricing, withholding tax, US tax treaties and partnership compliance, including familiarity with the financial statement impact of tax matters
• Strong working knowledge of and experience with OECD Pillar Two rules, country-by-country reporting requirements, and related global minimum tax frameworks
• Experience managing domestic and foreign tax matters, including corporate taxation, partnership taxation, accounting methods, tax treaties, permanent establishment and VAT (planning, compliance and disputes), and withholding taxes
• Extensive experience leading M&A transactions, specializing in Subchapter C, partnership taxation, and post-acquisition integration
• Significant experience advising on the tax implications of financing transactions and capital structures in a multinational context
• Proven ability to lead tax support of corporate initiatives from inception, planning, approval, execution, and review by external auditors and tax authorities
• Proven ability to build strong cross-functional relationships, including across tax, legal, controllership, treasury,…