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Manager, Tax - Aircraft Transactions - 33923

Location: DUBLIN, D, Ireland
Posting Start Date: Feb 13, 2024
Posting End Date: Feb 27, 2024

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Job Description

Description

Being part of Air Canada is to become part of an iconic Canadian symbol, recently ranked the best Airline in North America. Let your career take flight by joining our diverse and vibrant team at the leading edge of passenger aviation.

The Manager, Tax Aircraft Transactions is responsible for managing global income and transactional tax risks in relation to (i) aircraft transactions, including purchases/sales, leases, financings and re-financings and (ii) other ad-hoc international tax projects. 

Air Canada is currently undergoing a major fleet renewal and expansion program to serve new markets. The large number of new aircraft deliveries and disposals in various jurisdictions this year and over the next few years is creating a demand for international transaction tax advice across several jurisdictions. This requires an experienced Manager, Tax Aircraft Transactions to quickly identify and assess the tax consequences with an aim to negotiating aircraft transactions that protect Air Canada from a global tax perspective. Because aircraft are mobile across jurisdictions, this can subject aircraft transactions to a multitude of indirect taxes such as Value Added Tax (VAT), customs fees, duties or other charges. The responsibilities of the Manager will also include contract review and recommending solutions to minimize Air Canada’s tax exposure related to aircraft transactions. The Manager must possess a solid understanding of complex international aircraft structures in order to identify and address Canadian and foreign tax issues. Significant number of new aircraft deliveries over the next several years will require new financings or re-financings, the tax consequences of which will also be under the responsibility of the Manager.

As this position requires the incumbent to work closely with a number of departments within Air Canada, including but not limited to, Legal, Finance, Treasury, Aircraft Program, Maintenance, etc., constant and clear communication with the Director, executives and senior management is essential.

The incumbent will be responsible for assisting Senior Management with other ad-hoc international tax projects.

Accountabilities (Responsibilities):

  • Assess tax implications of all proposed aircraft related transactions and propose solutions to minimize tax implications 
  • Review term sheets and agreements relating to aircraft including purchase, sale, lease, sub-lease, lease extension, novation, financings and re-financings 
  • Assess Air Canada’s tax risks in foreign jurisdictions in connection with aircraft transactions 
  • Stay abreast of current developments in area of aircraft financing and structuring around the world and brief the Director on salient developments 
  • Coordinate with the Air Canada Legal department and external advisers on foreign tax issues 
  • Assist the Director with the development and implementation of appropriate guidelines/procedures to ensure that Air Canada and its subsidiaries are in compliance with any tax covenants and foreign tax reporting requirements imposed on Air Canada under aircraft agreements 
  • Liaise with Finance, Procurement, Maintenance, Aircraft Programs, Legal and other departments, including Air Canada rouge, as required on international tax issues.

Efforts:

  • Excellent interpersonal skills 
  • Ability to work in a highly dynamic environment and under pressure 
  • Strong analytical skills combined with a demonstrated ability to handle multiple files 
  • Sound judgment, organizational and decision-making skills 
  • Strong business acumen 
  • A results driven, dedicated team player who possesses a strong work ethic 
  • Excellent communication skills, oral and written 
  • To succeed in this role, the incumbent should be curious, flexible, perseverant and capable of handling situations with tight deadlines in a rapidly changing environment.

Working Conditions:

Very small team onsite – will be required to work 3 days per week at the airport office, 2 days from home.

Qualifications

  • Degree in Law, Business, Accounting or Finance 
  • CTA/AITI qualified (finalist may be considered with relevant experience) 
  • Minimum 5 years of experience in tax with significant experience in interpreting and analyzing tax legislation 
  • Experience in aircraft transactions with a focus on tax, a distinct advantage  
  • Must possess detail knowledge of different aircraft transactions, including but not limited to, purchase/lease/financing structures (e.g., Enhanced Equipment Trust Certificate, Conditional Sales Agreement, Special Purpose Entities, Sale/Leasebacks, Financing Leases, etc.) 
  • Knowledge and experience in international taxes including indirect taxes 
  • Significant experience interpreting and analyzing tax legislation 
  • Significant knowledge of, and experience interpreting, Tax Treaties and Bilateral Agreements (e.g., Avoidance of Double Taxation Agreements) 
  • Experience in assessing the experience of foreign counsel and advisors is an asset 
  • Knowledge of US income tax and state sales and use tax is an asset

Conditions of Employment:

  • Candidates must be eligible to work in the country of interest, at the time any offer of employment is made and seeking any required work permits/visas or other authorizations which may be required is the sole responsibility of the candidates applying for this position.

Linguistic Requirements

Based on equal qualifications, preference will be given to bilingual candidates. English required, French an asset.

Diversity and Inclusion

Air Canada is strongly committed to Diversity and Inclusion and aims to create a healthy, accessible and rewarding work environment which highlights employees’ unique contributions to our company’s success.

As an equal opportunity employer, we welcome applications from all to help us build a diverse workforce which reflects the diversity of our customers, and communities, in which we live and serve.

Air Canada thanks all candidates for their interest; however only those selected to continue in the process will be contacted.

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