Tax Senior

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Tax Senior
The candidate should have Bachelor's (or higher) degree in Finance, Accounting, Law, Business Administration, or a related field (willing to accept foreign education equivalent). Eighteen months of experience performing tax planning, reporting, and compliance for U.S. multinational corporations. Experience must include eighteen months of Preparing international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8865, and 8858 disclosures and statements. Analyzing work papers to calculate Section 861 deductions, interest expense allocation, and effectively connected income (ECI) to estimate the U.S. income tax liability of foreign corporations. Advising clients on various international tax issues, including subpart F, overall foreign loss, outbound transfer and inversions, and developing optimal tax structures for corporate restructuring, corporate reorganization, and mergers and acquisitions. Writing tax memoranda to determine whether certain foreign entities' activities constitute a permanent establishment in the United States and what portion of income may be subject to U.S. federal income tax. Performing tax due diligence to identify tax attributes and propose optimal capital distributions to maximize foreign tax credits and reduce effective tax rates. Reviewing proposed merger and acquisition documents and client data to identify contributions to foreign corporations and comply with Form 926 requirements. Utilizing CCH, BNA, LexisNexis, Thomson Reuters, and RIA Checkpoint to identify complex tax issues, research various U.S. federal income tax issues, and analyze tax rules and regulations of foreign jurisdictions. Utilizing Integrated International Tax Reform modeling to prepare quarterly tax provision calculations, calculating tax reform attributes, and projecting future planning opportunities; and Preparing work papers on various international tax issues, including global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), base erosion, and anti-abuse tax (BEAT) planning.

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