Tax Senior Manager, Infrastructure Asset Management in Dallas, Texas at Pacifico Energy LLC

Pacifico Energy Group is seeking a Tax Senior Manager to lead tax compliance, planning and reporting for our funds, management company and investment structures, including legal entity management, tax review of fund and transaction contracts, and the U.S. indirect tax function for project entities. The role reports to the Group CFO and works closely with fund accounting, project finance, legal and development teams. The role will be based in Dallas, Texas.

You will own the end-to-end tax lifecycle for the parent company and a growing portfolio of energy infrastructure project companies, from annual federal and California compliance and partnership filings through K-1 delivery to equity investors, while serving as the go-to tax advisor for development, project finance and investment teams.

Tax compliance and reporting

• Coordinate with Big 4 tax advisors to prepare and review U.S. federal and state partnership tax returns for energy and infrastructure funds and their underlying entities, managing timelines, data requests and review of workpapers.
• Oversee investor tax reporting, including Schedules K-1 and K-2/K-3, state K-1 equivalents and investor tax estimates, and respond to investor tax inquiries.
• Coordinate U.S. international information reporting for fund investments in Japan, Vietnam and Korea, including Forms 5471, 8865, 8858 and 8621, GILTI/Subpart F calculations, foreign tax credit information and FBAR filings, as applicable.
• Work with local advisors to oversee in-country tax compliance in Japan, Vietnam and Korea, including corporate income tax, withholding tax, and to make sure local results flow correctly into U.S. reporting.
• Support energy tax credit reporting, including credit calculations, allocations to partners and transferability elections, in coordination with the funds’ tax equity and transaction teams.
• Monitor treaty positions, entity classification elections and structuring changes. Manage tax notices, audits and partnership representative responsibilities under the centralized partnership audit regime (BBA).
• Maintain a compliance calendar, controls and documentation across all jurisdictions, and support tax-related items in fund financial statements and audits.
• Review partnership allocations, including waterfall, profit interest and Section 704(b)/704(c) capital account calculations.
• Manage Section 754 elections, Section 743(b) and 734(b) basis adjustments, and Pass-through entity tax elections.

Tax planning and structuring

• Advise investment teams on structuring funds, acquisitions, dispositions and financings, including blocker and holding company design.
• Lead tax diligence and planning for new investments, strategies and jurisdictions, and identify planning opportunities across the portfolio.
• Lead tax input on forming funds, blockers, holding companies, project SPVs and management company affiliates, including entity type and jurisdiction.
• Make and document check-the-box elections (Form 8832), obtain EINs and handle state tax registrations.
• Maintain the legal entity chart and each entity’s tax profile, and coordinate with internal or external counsels on formations, mergers and dissolutions.
• Review fund documents (LPAs, LLC agreements, subscription documents) and transaction and project agreements (purchase, financing, EPC, procurement, service and land option agreements) for tax efficiency.
• Negotiate and draft tax provisions, including allocations, distributions, tax distributions, withholding, indemnities and BBA audit clauses.
• Track legislative and regulatory developments and assess their impact on the funds and investors.

U.S. indirect tax

• Manage the U.S. indirect tax function, including sales and use, property, franchise, gross receipts and other non-income taxes, with a current focus on Texas sales and use, property and franchise (margin) tax.
• Determine the taxability of purchases, services and EPC/construction contracts, manage exemption certificates, and oversee use tax accruals on major equipment and materials.
• Oversee property tax renditions, assessments, appeals and abatement agreements, and help secure state and local incentives (e.g., JETI, energy and data center exemptions) during project development.
• Manage indirect tax filings, registrations, nexus reviews, notices and audits across all jurisdictions where the company operates, and manage exposure through reserves and voluntary disclosure agreements, working with external providers where needed.
• Build and maintain indirect tax processes, controls and systems, including tax engine and ERP tax configuration, as the company scales.
• Advise on indirect tax implications of project structures, acquisitions and dispositions, and of tax provisions in EPC, power purchase and customer contracts.

Required Qualifications

• Bachelor’s degree in accounting, finance or a related field.
• CPA license, or an attorney with a tax focus who is admitted and in good standing.
• 8 to 12 years of progressive tax experience, including significant time at a Big Four or national accounting firm and/or in an in-house asset management or infrastructure tax function.
• Deep knowledge of Subchapter K partnership taxation, including waterfall allocations, Section 704(b)/704(c) capital accounts, Section 754 elections and basis adjustments, and BBA audit rules.
• Hands-on experience with fund and blocker structures, including forming new entities, entity classification elections, and reviewing fund, transaction and project documents for tax efficiency.
• Proven experience managing outside advisors and reviewing complex partnership returns, K-1 and K-2/K-3 packages across many entities and deadlines.
• Working knowledge of U.S. indirect tax, including sales and use, property and franchise (margin) taxes, ideally in Texas.

Preferred Qualifications

• Master’s in Taxation (MST) or LL.M. in Taxation.
• Experience with energy, infrastructure or real asset funds, including energy tax credits, transferability and tax equity structures.
• International tax knowledge, including GILTI, Subpart F, PFIC, foreign tax credits, withholding and treaty matters, and experience coordinating in-country compliance, ideally in Asia (Japan, Vietnam or Korea).
• Experience with construction and procurement sales tax, property tax abatements or state and local incentive programs.
• Experience with IRS and state audits and voluntary disclosure agreements.
• Proficiency with tax software (e.g., CCH Axcess, GoSystem, OneSource) and advanced Excel; exposure to tax engines, ERP tax configuration or automation tools.

Skills and Competencies

• Technical judgment: reads complex fund documents and translates them into accurate tax outcomes.
• Communication: explains tax issues clearly to deal teams, executives and investors who are not tax specialists.
• Ownership: manages multiple deadlines across many entities with minimal supervision.
• Attention to detail: catches allocation, basis and reporting errors before they reach investors.
• Business partnership: works alongside fund accounting, legal and investment teams as a trusted advisor, not a back-office function.