Pagaya Director Tax 

United States, New York, New York 

391204507

Responsibilities

• Tax Planning & Strategy: Lead the development and implementation of tax planning strategies for U.S. and international operations, including structuring and advising on cross-border transactions, mergers and acquisitions, asset-backed securities, and capital markets activities.
• International Tax Compliance: Oversee and manage the external advisors preparation and filing of U.S. and international tax returns, including Forms 5471, 8858, 5713, and 1118 FTC, ensuring compliance with global tax requirements. Manage U.S. reporting of international income taxes, including GILTI, BEAT, FDII, Subpart F, and other provisions.
• Transfer Pricing: Lead transfer pricing planning and compliance, including documentation, local country reporting, and compliance with BEPS (Base Erosion and Profit Shifting) standards. Work with external advisors on transfer pricing reviews and agreements, ensuring the implementation of OECD guidelines.
• Tax Treaties & Structuring: Analyze tax treaties, evaluate their impact on the company’s cross-border activities, and advise on structuring opportunities to minimize tax exposure. Provide guidance on international tax structures, including those related to acquisitions, repatriation, and financing arrangements.
• Business Advisory: Partner with key internal stakeholders—finance, accounting, legal, treasury, and HR—to assess and advise on the tax implications of business strategies, such as new market entries, financing structures, capital flows, and tax-efficient global operations. Support tax-related aspects of strategic business decisions.
• IRS & Tax Authority Audits: Manage and respond to IRS audits for international tax matters and assist local tax managers in addressing tax audits in other jurisdictions. Prepare and maintain documentation for international tax positions in accordance with FIN 48 and other reporting requirements.
• State Tax & Legislative Advocacy: Monitor and analyze state tax legislation, assess its potential impact on Pagaya, and provide input for legislative responses. Collaborate with government relations teams to advocate for tax positions that align with Pagaya's interests.
• Tax Reporting & Financial Statements: Provide tax-related information and analysis for financial reporting, including U.S. GAAP tax provisions (ASC 740) and support the annual tax provision process. Oversee and coordinate the accounting for income taxes in multiple jurisdictions.
• Cross-Functional Leadership: Work closely with internal teams to address tax issues related to business models, cash management, tax-efficient repatriation, minimizing permanent establishment (PE) exposure, and optimizing effective tax rate (ETR). Ensure cross-functional alignment on tax matters and mitigate potential risks.
• Additional Projects: Take on special projects as needed, leveraging your tax expertise to provide strategic insights and drive the company's global tax strategy forward.

Requirements

• JD (licensed in the U.S., preferably NY or CA) and CPA or LLM in taxation preferred. An MST (Master of Science in Taxation) or equivalent education will also be considered.
• A minimum of 8+ years of experience in international tax, with a background in law firms, multinational corporations, or public accounting. Financial services or fintech experience is a plus.
• Extensive knowledge of corporate, international, and transfer pricing tax matters, including U.S. federal and state tax laws, as well as international tax principles (e.g., GILTI, BEAT, transfer pricing, and tax treaties).
• Expertise in tax planning, tax compliance, and tax reporting, with the ability to think strategically and develop practical solutions. Strong experience with U.S. GAAP tax provisions (ASC 740), international tax compliance (Forms 5471, 8858, etc.), and BEPS reporting.
• Strong command of Microsoft Office Suite (Word, Excel, PowerPoint), and familiarity with tax research platforms such as RIA, BNA, and Lexis Nexis.
• Strong interpersonal skills, with the ability to build relationships across all levels of the organization. Exceptional written and verbal communication skills are essential for presenting complex tax issues in an understandable and actionable manner.
• Strong judgment, critical thinking, and problem-solving abilities. Ability to work independently and manage multiple priorities in a fast-paced environment.

Our Values

• Continuously Learn - We challenge ourselves for the sake of getting better as individuals, as teams, and as an organization to deliver for our partners.
• Debate and Commit - We respectfully and openly debate to strengthen our ideas and build shared conviction - once we decide, we go all in, together.
• Dream Big and Act - We boldly tackle complex problems, pressure-test solutions in real-time, and adapt with speed and energy.
• Advance Inclusion - We create a world where everyone can win, designing systems that better represent people and generate sustainable value for our employees, partners and investors.
• Be Accountable Together - We proudly own our actions and our results, taking initiative to ensure our work gets over the finish line as a team.