Deloitte Tax LLP – $99,570.00/Year

Bachelors degree in Accounting, Finance, Law, Business Administration, or related field willing to accept foreign education equivalent plus five years of experience performing tax planning, reporting and compliance for U.S. multinational corporations. Experience must include five years of preparing international tax compliance forms and informational returns, including Forms 1118, 1120F, 5471, 5472, and 8858 disclosures and statements; analyzing work papers to calculate Section 861 deductions, including the review of corresponding interest expense allocation and income sourcing requirements, to estimate the U.S. income tax liability of foreign corporations as it relates to foreign tax credit generation and utilization capacity analysis; advising clients on various international tax issues including subpart F, overall foreign loss and outbound transfer, and developing optimal tax structures for corporate restructuring, corporate reorganization, mergers and acquisitions; advising clients on issues related to 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 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, Lexis Nexis and RIA Checkpoint to research various U.S. federal income tax issues, changes in regulations and analyze tax rules and regulations of foreign jurisdictions; performing international tax forecasting and modeling to assist clients with foreign tax credit planning; performing review of quarterly client Section 904, Section 861, Section 163j, GILTI, BEAT and FDII provision workpapers and assisting with the review of international tax yearend provision workpapers; and assisting with various international tax planning projects, including IP Valuation, Foreign Tax Credits, Interest Expense Apportionment, and Acquisition and Restructuring leveraging modeling tools. In the alternative, the employer is willing to accept a Masters degree and three years of experience as stated above. Position requires 15 domestic travel.br br From H. 10B due to character limitation Tax Manager or related occupation gaining experience performing tax planning, reporting and compliance for U.S. multinational corporations.