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About the Role

As our Senior Manager, you will provide international transaction tax services, including tax structuring, tax due diligence, and tax modeling, to a diverse range of high-profile clients. This role offers the opportunity to work on varied projects and gain excellent career development exposure.

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 modeling, 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 partnerships issues, access to foreign income tax offsets, and 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 to ensure tax considerations are appropriately reflected throughout the investment lifecycle.

Requirements

Extensive experience advising superannuation funds or large institutional investors on investment transactions and international tax matters.
Strong understanding of the taxation of offshore investment structures including Delaware LPs, Luxembourg structures, English Limited Partnerships, and other internationally used investment vehicles.
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.
Strong transaction execution capability, including tax due diligence, structuring, modeling, and negotiation of transaction documentation.
Commercially focused with the ability to explain complex international tax issues.
Proven ability to develop trusted relationships with clients, domestic and international teams.
Advising superannuation funds (either at a Big 4, law firm, or in-house) on offshore capital deployment across private equity, infrastructure, property, and credit strategies.
Experience with US tax issues relevant to superannuation investors, including treaty claims, partnership investment, and REIT structures.
Familiarity with the practical operation of superannuation industry investing, including documentation negotiation, tax compliance obligations, and investment implementation processes.
Experience coordinating global teams to support cross-border transactions and ongoing asset management.

Skills

International transaction tax
Tax structuring
Tax due diligence
Tax modeling
Superannuation fund advising
Institutional investor advising
Investment transactions
International tax matters
Offshore investment structures
US tax issues
Treaty claims
Partnership investment
REIT structures
Cross-border transactions
Transaction execution
Client relationship management
Team coordination

Location

Warrang - Sydney
Naarm - Melbourne

Work Type

Hybrid
Flexible work arrangements
Reduced hours

Experience Level

Senior Manager

Salary/Compensations

Competitive salary, open to negotiation pending on skills and experience.

Benefits

Yearly wellness incentive
Access to additional 8 weeks of flex leave per year
Family-friendly policies
Up to 26 weeks of gender-neutral paid parental leave

About the Company

EY is a leading provider of Tax services globally, nationally, and locally.
EY is the #1 deal advisor in Asia-Pacific on value and volume of deals for the tenth consecutive year based on 2022 Merger market data.
EY is the only Big Four firm with a separate business unit focused solely on the financial services industry (FSO).
EY is recognised as the #1 WORK180 Endorsed Employer in the Top 101 Employers for Women 2026.

Equal Opportunity

Inclusiveness is core to who we are and how we work together, driving value for our people and for our business.
We encourage applications from people of all ages, nationalities, abilities, cultures, sexual orientations, and gender identities and are committed to providing an equitable and barrier free recruitment experience for all.
We encourage you to share any support and adjustments you need to be your best and participate equitably in our recruitment process.
Anything you tell us will be kept completely confidential.