Bachelors or higher degree in Finance, Accounting, Law, Business Administration, Economics, or related field willing to accept foreign education equivalent plus 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, 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 Thomson Reuters, Go Systems, OneSource, Corptax, CCH, BNA, Lexis Nexis, and RIA Checkpoint to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions; auditing client prepared work papers, including foreign tax credit and deferred tax asset utilization capacity analysis; researching US Federal income taxation of international operations, including US tax reform with special interest in GILTI, the GILTI hightax exception, and foreign tax credits; and preparing and auditing quarterly and annual income tax provisions, including uncertain tax positions, valuation allowances, transfer pricing principles, indefinite reinvestment assertions, and financial statement footnote disclosures. Less than 10 travel outside of normal commuting distance.br br From H.10B. due to character limitation Tax Senior or related occupation gaining experience performing tax planning, reporting and compliance for U.S. multinational corporations.
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