International Tax Senior Manager

Profile

International Tax Senior Manager

Duties: Provide US-outbound tax planning support for international operations of US-headquartered companies, including repatriation strategies, foreign tax credit optimization, and local country tax planning opportunities. Prepare and review quarterly and annual international ASC 740 (FAS 109/FIN 48) tax accruals, global effective tax rate calculations, and footnote disclosure. Prepare and review Forms 5471 for controlled foreign corporations, Forms 8858 and 8865 for flow through foreign entities, Forms 1120, 1065 1120-S for U.S. companies with foreign operations, Form 1120-F for foreign corporations with U.S. trades or business/permanent establishments, and Forms 5472, 8804/8805, 1042/1042-S, 8828/8288-A/8288-B, etc. Prepare, review and assist in maintaining supporting documentation of earnings and profits pool, tax pool, PTI, and US tax basis for foreign subsidiaries and/or branches of US multinationals. Analyze and calculate taxable distributions, 987 gains/losses, Subpart F income, ECI, Global Intangible Low Taxed Income, CFC attribution, Section 245A Deduction, hybrid transactions, 163(j), FDII, etc; support the preparation of Forms 1118 and 1116 for foreign tax credits and supporting documentation; and determine and maintain supporting documentation for 861 allocations to foreign source income. Prepare and review required elections and disclosures such as check-the-box elections, DCL’s, etc., as well as maintain tax basis balance sheets. Assist in the design and review of intercompany pricing policies for clients on products and services, and work with the transfer pricing group to review transfer pricing reports and related compliance filings. Coordinate and assist clients with local reporting and filing requirements of foreign subsidiaries and foreign branches, determine PFIC status and prepare related computations, and assist in tax audits management and defense. Organize and document restructuring and other planning initiatives including the preparation of power points slides, work plans or project timelines, technical memorandums, letters, opinions, and ruling requests. Support the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses.

Additional Information

Req ID: 11815

Company info

CBIZ, Inc.
56 Exchange Terrace 5th Floor
Providence
Rhode Island
United States 02903
Website : http://www.cbiz.com