Manager, IRS/DOE Tax Credit and Loan Compliance

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Job Summary

The Manager, Supply Chain –Tax Credit & Loan Compliance leads the Supply Chain compliance team, which coordinates IRS tax-credit and DOE Loan compliance for the Nuclear Uprate program and other major projects. This role leads internal compliance efforts, coordinates externally across contractors and vendors, and serves as the coordination point with operations, HR, tax, legal and treasury.

The manager is responsible for ensuring all vendors/contractors are compliant with their IRS tax credit and DOE loan contractual obligations, contractor onboarding with Vistra’s third-party payroll provider, engagement with Vistra’s third-party tax and loan consultant, escalating/resolving non-compliance issues, and providing status reports in accordance with the program governance structure and process.

The role focuses on program management and operationalizing contract compliance and while becoming deeply familiar with the regulatory requirements of: Davis-Bacon Act, Prevailing Wage and Apprenticeship, Cargo Preference Act, Material Assistance Domestic Content. The Manager may also lead, develop and mentor procurement and compliance analysts within Supply Chain.

Job Description

Key Accountabilities:

Compliance Program Leadership & Governance

Leads the Supply Chain compliance team efforts to support the nuclear uprate tax credit and DOE loan compliance; maintain and continuously improve the compliance governance model and RACI.

Define and document compliance outputs with Treasury, Tax and PMO, including required DOE and IRS reports, reporting cadence, contractor source data and escalation processes for missing information.

Serve as the primary point of contact for external compliance consultants. Responsible for overseeing consultants scope; deliverables; budget; and consultants’ engagement with other Vistra workstreams (e.g. Tax, Treasury, etc.).

Ensure Treasury, Tax and Legal retain accountability for their regulatory obligations (DOE interactions, tax filings, certifications and final compliance signoffs) while Supply Chain manages technical deliverables supporting regulatory sign-off

Coordinates and own selection, implementation and operations of payroll/compliance tracking systems.

Contracting & Commercial Compliance

Ensure all applicable compliance contract language and exhibits (DBA, PW/A, FEOC/material assistance, domestic content, Cargo Preference Act), are included in applicable contracts or PO’s; including flow-down of obligations to subcontractors.

Maintain a contract-by-contract tracker of applicable compliance requirements, including negotiated changes to withholding, indemnity, penalty, cure-payment and flow-down provisions.

Partner with IT and Major Projects to embed compliance classification at requisition and PO line level so requirements drive the correct contract exhibits and tracking lists; ensure third-party purchasing partners include required terms and data requirements on POs they place.

Initiate commercial action against contractors for unresolved compliance deficiencies, in coordination with Tax, Treasury and Legal.

Coordinate with contract owners to remedy missing contractual obligations or deliverables.

Contractor Onboarding, Reporting & Issue Resolution

Develop and maintain vendor-facing compliance playbooks and instructions (Davis-Bacon, Cargo Preference Act, FEOC and material assistance) that clearly describe what vendors must submit and when.

Drive contractor and subcontractor onboarding, including providing payroll-system and consultant reporting links and supplying consultants with contractor/subcontractor names and contact information.

Request and follow up on supplier cost, and origin information, ensuring the collection, safe harbor certificates and direct cost submissions; as applicable, coordinate consultant access to contractors when noncompliance or questions are flagged, and drive the resolution of all noncompliance issues.

Coordinates with PPMO to ensure weekly reconciliation of badging and site access data to certified payroll submissions.

Monitor apprenticeship ratio and overall project apprenticeship requirements using consultant reports, coordinating with noncompliance contractors to ensure apprenticeship ratios can be adjusted while work is ongoing to avoid penalties.

Coordinate with HR to map Vistra employee job descriptions to DOL wage classifications (consulting a DBA attorney when needed) and ensure applicable payroll records are submitted to the payroll provider.

Deficiency Remediation & Cure Payments

Oversee the cure-payment process for both Tax and Treasury requirements: determine whether cure is a contractor or Vistra obligation under each contract, coordinate with contractors/subcontractors and HR to ensure timely payment, and collect proof of payment.

Track and escalate compliance deficiencies flagged by consultants through confirmation, cure decision and closure.

Materials, Sourcing & Shipping Compliance

Provide Tax with the list of all planned project materials and maintain the tracked manufactured product and component list and vendors providing such materials; notify Tax of changes so that the correct categorization is applied.

Ensure all project costs are appropriately scoped with domestic content and FEOC data collection.

Coordinate collection of shipping documentation (e.g., bills of lading) to support Cargo Preference Act compliance for Treasury.

Audit Readiness, Policy & People

Ensure compliance artifacts are collected, retained and audit-ready for the required obligation periods (including post-placed-in-service requirements).

Develop, manage and report compliance with key performance indicators and status reporting in accordance with program governance structure and process.

Responsible for upholding internal and external policies, regulations and laws; alerting program Executive Steering Committee of emerging compliance risks.

Incorporate safety into daily work ethic and buying decision process.

Lead, coach and develop procurement and compliance analysts; make process improvement recommendations to Supply Chain leadership.

Education, Experience & Skill Requirements:

Bachelor's degree in Supply Chain Management, Business, Finance, Accounting, Law/Paralegal Studies or a related field, or equivalent experience.

Minimum 8 years of relevant program management, procurement, contracting, commercial compliance experience, including at least 3 years leading people, teams or complex cross-functional programs.

Experience with government-funded or regulated programs (e.g., DOE loan programs, IRA tax-credit compliance, Davis-Bacon prevailing wage, apprenticeship, domestic content, FEOC or Cargo Preference Act requirements) preferred.

Experience supporting major capital, construction or nuclear/power generation projects preferred.

Demonstrated expert understanding of contract Terms & Conditions, including flow-down, indemnity, withholding and remediation provisions.

Proven program/project management skills; ability to coordinate multiple stakeholders, manage reporting requirements and drive issue escalation to resolution.

Strong written and oral communication; ability to negotiate with and influence contractors, internal stakeholders and senior leaders.

General business knowledge and acumen, with broad-based knowledge of program management, sourcing, procurement, contracting and stakeholder/supplier management processes.

Experience with purchasing and contract systems (e.g., Maximo, Conga CLM) and certified payroll/compliance tracking platforms (e.g., LCP Tracker) preferred.

Advanced Microsoft Office capabilities (PowerPoint, Word and Excel); experienc