CFC and Foreign Income Inclusion Remediation Director

The mandate

The interim Director will recover control of controlled-foreign-corporation and foreign-income inclusion calculations whose entity facts, attributes and reporting data are not consistently reconciled. The task begins within four weeks and covers the calculation, evidence and accounting interface required for a defensible cycle. It does not extend to a redesign of the entire international tax structure.

The first month will verify entity classification, ownership periods, elections, tested-income or equivalent attributes, taxes, distributions, financing and source records. Calculation differences will be traced to fact, interpretation, data mapping, currency or version change. The Director must identify where prior expedients became recurring methods without explicit approval.

Temporary authority includes setting the recovery calendar, assigning factual and computational owners, returning unsupported work, approving routine corrections within delegation and escalating elections or material tax-accounting conclusions. Structural transactions, formal elections, filed-return signature and legal opinions remain reserved. Unrelated transfer-pricing and indirect-tax projects are excluded.

Handover requires a permanent leader to direct one full calculation and one subsequent refresh, including resolution of a late entity or data change. Departure evidence comprises an accepted entity map, controlled models, election register, reconciliation, issue log, accounting bridge and forward calendar. The Chief Tax Officer must sign that residual judgments have owners and dates.

What you will own

• Reconcile the controlled-entity population, ownership periods, classifications, permanent establishments and elections to legal and filing records.
• Reconstruct material inclusion calculations from governed financial and tax data, documenting transformation, currency, attribute and tax-credit treatment.
• Identify recurring shortcuts, overlays and inherited elections whose authority or continued technical basis cannot be demonstrated.
• Establish change control for entity events, law updates, amended source values, model versions and post-close corrections.
• Reconcile calculated inclusions to return positions, tax provision, deferred-tax treatment and cash forecast through separate, explicit bridges.
• Direct correction and retesting of critical model or data defects before work enters filing or reporting approval.
• Prepare permanent owners through a complete live cycle and a simulated late ownership or data change.
• Transfer a signed recovery dossier containing approved facts, calculations, elections, residual issues and next-cycle responsibilities.

Candidate qualifications

• At least 16 years in US international tax or comparable foreign-income inclusion regimes, including Director-level remediation responsibility.
• A controlled-entity population or calculation defect you found, its tax and accounting consequence, and how completeness was reproved.
• Deep working knowledge of CFC classification, ownership, income categories, attributes, credits, elections, distributions and provision interaction.
• Evidence of distinguishing a technical-method change from a source-data correction and ensuring each received the right approval.
• Experience governing complex calculation models through specifications, source lineage, version control, review and defect retesting.
• A case where you challenged continued use of an inherited election or shortcut whose original authority could not be established.
• Proven transfer of calculation leadership through live successor operation under late-changing facts.

Working terms and boundaries

• The eleven-month engagement runs five days a week; a one-month extension is permitted only for an incomplete successor-led controlled review.
• The interim controls recovery process and delegated corrections, while structure, elections, return signature and reserved accounting remain elsewhere.
• Broad restructuring, unrelated transfer pricing, indirect tax and technology replacement do not enter the assignment scope.
• Chicago presence is required for model reconstruction and the first controlled cycle; travel follows specific evidence-owner needs.
• Completion requires successor-run calculations, controlled models, reconciled accounting bridges and accepted ownership of every residual judgment.

Application

Applications for this mandate are received in one way only: through the India Board Terminal's application process. It is automated end to end. Your Executive Passport travels to the mandate holder in its confidential form, your answers to the three questions below are read before anything else in your file, and every stage that follows is recorded on your applications page.

There is no address to write to and no intermediary to call. The mandate holder reads what the Terminal delivers and nothing else, which is what keeps the process the same for every applicant and keeps your name out of it until you release it. Applications close on 10 October 2026. Mandate reference TAX-INT-2026-CHI-30.