This organization is investing heavily in modernizing its international tax function, and is looking for a senior tax professional to lead Canadian international tax compliance for a large and complex portfolio of foreign subsidiaries. This is a technical leadership role. The right person will be someone who has built a career specifically in international tax, who still works hands on in the detail of complex filings, and who can also operate at a senior level with executive stakeholders across the business.

Given the scale of the foreign affiliate portfolio involved, this role requires someone who has operated at real volume, not someone who has touched a handful of foreign affiliate filings over the course of their career. The organization is open to candidates whose current title sits at Assistant Director or Senior Manager if their experience and tenure reflect true readiness for a Director-level mandate.

What You'll Do

Lead the preparation and review of FAPI calculations and T1134 filings across a large, high volume foreign affiliate portfolio

Own surplus calculations, including T106 filings, and ensure accuracy across a complex multi entity structure

Determine and apply foreign affiliate versus controlled foreign affiliate status where ownership and control questions are complex

Translate the tax impact of foreign subsidiary activity into clear guidance for the Canadian parent organization, working directly with senior finance and business leaders

Lead the management of CRA audits related to international and foreign affiliate matters, including responding to queries and defending filing positions

Support major business initiatives, including acquisitions, divestitures, reorganizations, and treasury financing, with proactive international tax input





Stay ahead of legislative and regulatory change affecting foreign affiliate taxation and communicate impact to senior leadership before it becomes a compliance issue

Contribute to the adoption of new tax technology and process improvements as the function modernizes

What You Need

15+ years of progressive tax experience, with the majority of recent experience specifically in international tax

Demonstrated hands on experience with FAPI calculations and T1134 preparation and review within the last 12 months

Direct experience with high volume foreign affiliate compliance, gained inside the in-house tax function of a Canadian multinational organization, not solely through advisory work

Strong working knowledge of foreign affiliate and controlled foreign affiliate determinations A career background that includes time in a Big 4 international tax practice, followed by in-house experience at a Canadian multinational

CPA or equivalent designation, along with either completion of all three levels of the CPA In-Depth Tax Course, or a Master of Taxation

Comfortable remaining hands on in complex technical work while also operating at a senior strategic level A resume and career history that reflects genuine depth in international tax, not domestic tax experience with some international exposure layered in

What's In It for You

Join a team actively modernizing how international tax is managed, with real investment in technology and process

Work with leadership committed to your development, with a track record of promoting from within

Regular, meaningful exposure to senior executives across the organization

Competitive compensation, including performance bonus and versatile benefits A collaborative tax function rather than a siloed compliance role

📌 Director of International Tax (Toronto)
🏢 The Mirillion Group
📍 Toronto