Tax Manager – US Real Estate Partnerships (Argentina)

Tax Manager – US Real Estate Partnerships (Argentina)

08 nov
|
Bruntwork
|
Argentina

08 nov

Bruntwork

Argentina

Our client, a US private equity real estate firm, is seeking an experienced Tax Manager – US Real Estate Partnerships to oversee partnership tax compliance and reporting for a private equity real estate portfolio. In this full-time role reporting directly to the CFO, you will review approximately 70 partnership tax returns prepared by an outside CPA firm and prepare roughly 10 upper-tier Form 1065 returns in-house. You will handle complex partnership mechanics, including 704(b)/(c) allocations, 752 debt allocations, 754 elections, and multi-state K-1 investor reporting. Additionally, you will manage compliance calendars, tax distributions, and transaction support outside peak filing seasons.

Schedule

Monday - Friday, 8:00 AM - 5:00 PM EST, with 1 hour unpaid break (40 work hours per week)

Responsibilities

- Reviewing Outside Firm Returns (~70 Partnerships): Serve as the primary technical review layer between the outside CPA firm and the CFO, escalating only genuinely complex issues.
- Review Section 704(b) and 704(c) allocations to ensure tie‑outs to LPA waterfalls, proper application of targeted capital mechanics, and accurate tracking of built‑in gain layers.
- Audit Section 752 debt allocations across recourse, nonrecourse, and qualified nonrecourse debt, including the impact of partner guarantees on tax basis.
- Verify Section 743(b) step‑ups and Section 754 elections, reflecting mid‑year transfers of LP interests accurately.
- Review depreciation and cost segregation schedules, bonus depreciation, Section 163(j) limitations, and interest capitalization elections.
- Oversee investor‑side reporting, including UBTI for tax‑exempt partners, ECI and FIRPTA for foreign partners, state K‑1 footprints,



and composite/nonresident withholding.
- Draft authoritative review comments, deliver them to the outside accounting firm, and manage issues through to resolution.
- Preparing In‑House Returns (~10 Upper‑Tier 1065s): Prepare and file returns for upper‑tier partnerships receiving lower‑tier K‑1s.
- Build workflows to handle lower‑tier K‑1s arriving close to extended filing deadlines.
- Manage multi‑state filing, composite, and withholding footprints resulting from state‑sourced income flowing from lower tiers.
- Ensure flow‑through items (Section 163(j), Section 1061, UBTI, Section 704(c)) retain their proper tax character.
- Maintain partner capital accounts and accurate tax basis reporting.
- Supervise extensions, estimated payments, and compliance calendars across all internal entities.
- Year‑Round Strategic Tax Operations: Manage outside CPA firm engagements, standardizing PBC packages, delivering clean trial‑balance‑to‑tax workpapers, and controlling scope and fees.
- Oversee tax notices, annual reports, franchise tax filings, registrations, and entity housekeeping across 80+ entities.
- Calculate partnership tax distributions against LPA provisions and monitor quarterly estimates.
- Provide investor tax support, including responding to LP K‑1 inquiries, preparing UBTI/ECI estimates,



administering FIRPTA withholding, and managing W‑8/W‑9 collections.
- Deliver transaction and deal support, including purchase price allocations, cost segregation coordination, 1031 exchange tracking, and structuring input for acquisitions and dispositions.
- Coordinate portfolio‑wide property tax assessment tracking and appeals.

Requirements

- 7+ years of experience in US partnership taxation, with a dedicated focus on real estate or real assets.
- Substantial return review experience with a proven track record of identifying technical discrepancies and signing off on complex partnership returns.
- Deep technical command of Sections 704(b), 704(c), 752, 743(b), 754, 163(j), and tiered partnership structures.
- High confidence in challenging outside advisers and writing clear, actionable review notes.
- Exceptional written and verbal English communication skills suitable for direct collaboration with executive leadership and US partners.
- Ability to maintain necessary working hour overlap with US leadership during compliance windows.

Qualifications

- Active US CPA or Enrolled Agent (EA) credential preferred.
- Recognized accounting credential (such as CA or equivalent international certification).
- Experience with Big 4 or national public accounting firms.
- Exposure to REIT testing, blocker structures, or fund-of-funds reporting.
- Experience with Opportunity Zones or Section 1031 exchanges.
- Familiarity with professional tax compliance software and fixed asset management systems.
- Familiarity with state, local, or property tax administration.
- Permanent work from home
- Immediate hiring
- Health Insurance Coverage for eligible

📌 Tax Manager – US Real Estate Partnerships (Argentina)
🏢 Bruntwork
📍 Argentina

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