This role leads complex U.S. international tax engagements and broader client relationships, helping senior tax, finance, accounting, and business stakeholders navigate cross-border compliance, planning, transactions, and reporting. Provide senior-level guidance on Subpart F, NCTI, foreign tax credits, Section 163(j), FDDEI, BEAT, Section 245A, PTEP, tax treaties, withholding, repatriation, foreign currency matters, and cross-border structuring.