Job description:
Tax Manager – Canadian CPA Firm Position Summary
We are seeking an experienced, technically strong and highly independent Tax Manager to join our growing Canadian CPA firm.
This is a senior, hands-on position for a professional with a minimum of 7 years of practical Canadian public accounting and tax experience. The successful candidate must have strong working knowledge of Canadian taxation, Canadian accounting standards, CRA requirements, the Income Tax Act and relevant CPA Canada Handbook guidance.
The Tax Manager will be expected to independently manage complicated tax matters, review the work of accountants, handle CRA matters, provide practical tax planning advice, train and develop team members, and maintain a very high standard of accuracy and technical quality.
This position requires someone who can take ownership of difficult files with minimal supervision and who is comfortable researching and applying Canadian tax legislation to real client situations.
Key ResponsibilitiesCanadian Tax Compliance and Review
- Manage and review Canadian corporate income tax returns, including complex T2 corporate tax returns and related schedules.
- Review personal income tax returns, trust returns and other Canadian tax filings as required.
- Review tax calculations, supporting schedules and tax working papers prepared by accountants.
- Ensure tax returns are complete, technically accurate and compliant with applicable Canadian tax legislation.
- Handle complex tax files involving multiple corporations, shareholders, holding companies and related entities.
- Identify tax exposures, filing deficiencies and planning opportunities during the review process.
- Review Notices of Assessment and Notices of Reassessment and investigate discrepancies.
- Ensure elections, designations and other tax filings are completed correctly and within applicable deadlines.
- Maintain strong documentation supporting material tax positions and professional judgments.
Income Tax Act – Practical Technical Expertise
The successful candidate must possess strong practical experience interpreting and applying provisions of the Canadian Income Tax Act.
Practical experience should include a variety of areas such as:
- Section 85 rollovers and corporate reorganizations
- Section 86 share reorganizations
- Section 51 share conversions
- Section 55 intercorporate dividend considerations
- Section 84 deemed dividends
- Section 84.1 non-arm's-length share transfers
- Section 74 attribution rules
- Section 69 non-arm's-length transactions
- Section 15 shareholder benefits
- Associated corporation rules
- Small Business Deduction
- Aggregate Investment Income
- Adjusted Aggregate Investment Income
- Taxable capital calculations
- Capital dividend accounts
- Refundable dividend tax accounts
- GRIP and eligible dividends
- Intercorporate dividends
- Capital gains and capital losses
- Lifetime Capital Gains Exemption
- Qualified Small Business Corporation shares
- Safe income considerations
- Estate freezes
- Family trusts and trust taxation
- Holding company structures
- Business acquisitions and dispositions
- Residency and non-residency taxation
- Departure tax and immigration/emigration tax matters
- GST/HST considerations affecting owner-managed businesses
The Tax Manager is not expected to know every provision from memory but must demonstrate the ability to research, interpret and practically apply legislation to actual client situations.
Tax Research and Technical Analysis
- Research provisions of the Income Tax Act and Income Tax Regulations.
- Review CRA technical interpretations, folios, administrative policies and published guidance.
- Research relevant Tax Court of Canada and other tax jurisprudence where appropriate.
- Prepare or review technical tax memoranda.
- Document the technical reasoning supporting significant tax positions.
- Assess alternative tax structures and explain advantages, disadvantages and risks.
- Recognize when specialized legal or external tax advice is required.
- Remain current with changes to Canadian tax legislation, CRA administrative policies and significant court decisions.
CRA Coordination and Representation
- Act as a primary contact for CRA matters involving assigned clients.
- Independently manage CRA review letters and information requests.
- Coordinate and respond to CRA corporate and personal tax audits.
- Handle CRA payroll, GST/HST and income tax inquiries where applicable.
- Review proposed CRA adjustments and determine whether they are appropriate.
- Prepare supporting documentation and technical responses to CRA.
- Handle Notices of Assessment and Notices of Reassessment.
- Assist with Notices of Objection and other dispute-resolution matters.
- Coordinate requests for taxpayer relief, penalty and interest relief where appropriate.
- Communicate professionally and confidently with CRA officers.
- Maintain proper documentation of CRA discussions, submissions and correspondence.
- Escalate significant CRA disputes or exposures to senior management at an early stage.
Canadian GAAP and CPA Canada Handbook Knowledge
The Tax Manager must have strong knowledge of Canadian accounting principles applicable to private businesses and understand the interaction between accounting and taxation.
The successful candidate should have practical knowledge of:
- Canadian GAAP
- Accounting Standards for Private Enterprises – ASPE
- CPA Canada Handbook requirements relevant to private enterprises
- Financial statement presentation
- Revenue recognition
- Property, plant and equipment
- Intangible assets
- Investments
- Related-party transactions
- Income taxes
- Share capital
- Retained earnings
- Dividends
- Loans and financing arrangements
- Business combinations
- Accounting estimates
- Contingencies
- Subsequent events
- Intercompany transactions and balances
The Tax Manager should be able to identify situations where accounting treatment affects taxation and where tax adjustments differ from accounting treatment.
Experience with CSRS 4200 Compilation Engagements and understanding the relationship between financial statements, tax working papers and corporate tax returns is strongly preferred.
Complex Tax Planning and Advisory
- Provide practical tax planning advice to owner-managed businesses and their shareholders.
- Review corporate structures and identify opportunities for improved tax efficiency.
- Assist with corporate reorganizations and restructuring.
- Assist clients with holding company and operating company structures.
- Provide salary-versus-dividend planning.
- Assist with shareholder remuneration strategies.
- Review potential capital gains and available exemptions.
- Assist with succession planning and estate freezes.
- Participate in business acquisition and sale planning.
- Identify tax implications before significant transactions are completed.
- Work with lawyers and other advisors on tax-driven reorganizations and transactions.
- Explain complicated tax matters to clients in clear and practical language.
Team Management and Review
- Supervise and support accountants and other tax team members.
- Review tax work prepared by junior, intermediate and senior accountants.
- Provide meaningful and technically sound review comments.
- Ensure review points are properly resolved.
- Explain the reason behind corrections so team members improve technically.
Training and Development
The Tax Manager will play an important role in building the firm's internal tax knowledge.
Responsibilities will include:
- Providing regular Canadian tax training sessions.
- Training accountants on practical application of the Income Tax Act.
- Using actual client situations as internal case studies where appropriate.
Independence and Ownership
A critical requirement of this position is the ability to work independently.
The Tax Manager must:
- Take full ownership of assigned files.
- Manage files from planning through completion.
- Independently research unfamiliar tax issues.
- Not depend on the Partner or CEO for routine technical decisions.
- Follow up proactively with clients, CRA and internal team members.
- Monitor and manage deadlines without repeated reminders.
- Present potential solutions when escalating problems.
- Take responsibility for the quality of work reviewed and approved.
- Demonstrate strong professional judgment.
- Be comfortable making recommendations based on technical research and available facts.
Required Qualifications
- Minimum 7 years of practical Canadian accounting and tax experience.
- Significant experience working within a Canadian public accounting or CPA firm environment is strongly preferred.
- Canadian CPA designation is preferred.
- CPA candidates with exceptionally strong Canadian tax experience may also be considered.
- Completion or substantial progress toward the CPA Canada In-Depth Tax Program would be a significant asset.
- Strong practical understanding of the Canadian Income Tax Act and Income Tax Regulations.
- Practical experience applying multiple provisions of the Income Tax Act to real client situations.
- Strong understanding of CRA rules, administrative policies and filing requirements.
- Strong experience communicating and dealing directly with the Canada Revenue Agency.
- Strong understanding of Canadian GAAP and ASPE.
- Strong practical understanding of relevant sections of the CPA Canada Handbook.
Reporting Relationship
The Tax Manager will report to the Partner, CEO or designated senior management and will work closely with the firm's Accounting Managers, Accountants and other professional staff.
This position is intended for a technically capable professional who can become a key Canadian tax resource within the firm, independently handle difficult tax assignments, strengthen the technical capabilities of the accounting team and maintain a very high standard of quality across the firm's tax practice.
One important addition I made is the expectation of practical ITA application, rather than saying only “strong knowledge of the Income Tax Act.” For the type of Tax Manager you are looking for, that distinction is important - you want someone who can look at an actual corporate structure or transaction and know which sections could apply, what needs to be researched, where the risks are, and what should be done next.
