Foreign Tax Credit Model Director

The mandate

This project will build and validate a foreign-tax-credit model for a defined return and forecasting perimeter. The bounded problem is to reconcile foreign income, taxes, baskets or limitation categories, expense allocation, timing and carryforwards through a calculation that can be reproduced and governed. The assignment is not broad restructuring or return preparation.

Milestone one, due in week six, is an accepted inventory of credits, carryforwards, source data, legal restrictions and current calculations. Milestone two, at month three, is the rule specification and data dictionary. Milestone three, at month five, is an independently validated model with sensitivities and defect record.

Milestone four, at month seven, is a controlled pilot through production-representative data, including reconciliation to relevant return and tax-accounting views. Final acceptance at month eight requires the approved model, methodology, controls, operator assessment and residual-risk register. Technical acceptance sits with the International Tax Director; model-control acceptance sits with the tax-accounting owner.

The client provides filed returns, foreign-tax records, income sourcing, allocation data, carryforward schedules, financial statements and factual-owner access. Acceptance requires a reconciled population, correct categorisation, reproducible limitations, controlled versioning and closure of critical defects. Transaction structuring, legal opinions, filing submission and platform implementation are excluded.

What you will own

• Reconcile foreign taxes, income, carryforwards and expiry attributes to filings, authority evidence and tax-accounting records.
• Define categorisation, sourcing, expense allocation, limitation, timing and utilisation rules in a reviewer-readable specification.
• Establish treatment for amended values, contested taxes, currency, redeterminations and changes that require prior-period reconsideration.
• Build scenarios showing utilisation sensitivity to income mix, expense allocation, legal restrictions and forecast timing.
• Validate calculations independently through benchmark cases, boundary conditions and reconciliation to controlled source data.
• Run a live pilot and record whether differences arise from rule interpretation, source mapping, model defect or approved judgment.
• Test permanent operators through a redetermination and expiring-credit scenario before transferring the toolkit.
• Deliver accepted models, specifications, workpapers, controls, limitations and maintenance ownership.

Candidate qualifications

• At least 16 years in international tax or tax accounting, including Director-level foreign-tax-credit calculation and planning responsibility.
• A foreign-tax-credit result you materially changed after finding a categorisation, allocation, sourcing or redetermination error.
• Deep command of creditability, baskets or limitation categories, expense allocation, carryforwards, currency and redeterminations.
• Evidence of connecting filed foreign taxes to accounting and forecast models without treating different bases as errors.
• Experience validating a complex tax model through independent cases, boundary testing and source reconciliation.
• Ability to separate model engineering from transaction structuring and reserved technical conclusions.
• Fixed-project completion through a controlled pilot, operator test and separate technical and model-control acceptance.

Working terms and boundaries

• The eight-month project uses four days a week and releases fees through five accepted milestones.
• International Tax accepts technical rules; tax accounting separately accepts reconciliation, model control and operating evidence.
• Returns, tax records, allocation data, attributes, statements and owner access are scheduled client dependencies.
• Structuring, legal opinion, filing submission and production-platform implementation remain outside scope.
• Final acceptance requires a reproduced pilot, cleared critical defects, tested operators and signed residual limitations.

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 12 October 2026. Mandate reference TAX-CON-2026-CHI-56.