International Tax Manager

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International Tax Manager
The candidate will be gaining a deep understanding of business initiatives, models, goals, and drivers, including gaining a deep understanding of the technologies and/or intellectual property used to launch business initiatives./ Identifying and documenting business proposals. Assisting with designing and leading the implementation of optimal tax structures for various new business initiatives (e.g. income sourcing, income characterization, PE analysis, funding, currency issues, etc.). Assisting with developing strategies to minimize the potential Subpart F generated by proposed business models. Assisting with the evaluation of proposed business models with an aim at developing strategies to mobilize foreign cash, maximize tax effective foreign cash repatriation, and generally coordinate and liaise with the treasury department with respect to global cash management. Assisting with liaising with financial personnel as well as both US and foreign outside tax advisors. Assisting with developing strategies to optimize the use of foreign tax credits generated by proposed business models. Assisting with evaluating business proposals to identify strategies with respect to financing, dividends, and treaty opportunities. Writing technical and non-technical tax research and compliance memos. Writing detailed tax requirements to be used by various business partners throughout the company. J.D. or bachelor's degree in accounting (with CPA and/or MST preferred) is preferred. Should have 7+ years of experience in tax, finance or a related analytical field. Should have 7+ years of progressive international tax income tax experience in a large corporate environment and/or public accounting or large law firm

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