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General Description: International Tax Associate within a fast growing public accounting firm serving a broad range of both inbound and outbound clients from middle-market companies to publicly traded corporations. Our International Tax group is a nationalized group that acts as a technical resource to the rest of the firm regarding international tax matters. Thus, it is imperative that our International Tax group maintains a high degree of technical tax proficiency in order to adequately serve our clients and mitigate risk to our firm. Therefore, the candidate must have excellent tax research and writing skills. Additionally, the candidate must possess the ability to gather and decipher relevant facts and apply the tax law to the facts performing a critical analysis to arrive at a well-reasoned conclusion. Additionally, our International Tax group is very active in seeking out our own international tax opportunities within the Charlotte market and the Carolinas. Therefore, in addition to having excellent tax research, writing and analytical skills, the candidate is also expected to have a basic understanding of accounting and tax computational and reporting concepts and to be very comfortable in excel and power point. Responsibilities
- Research international tax issues using RIA Checkpoint and Westlaw. Will be expected to perform tax research tasks in an often short time-frame including the ability to quickly process private letter rulings, technical advice memorandums, field service advisories, revenue rulings, court cases, treasury regulations, internal revenue code sections, etc.
- Prepare and review technical tax memorandums including description of relevant facts, addressing of issue(s), adequate description of the relevant tax law using correct Blue Book citations, and logical analysis and conclusion.
- Treaty (particularly, Limitation on Benefits) and Foreign Account Tax Compliance (“FATCA”) analysis and preparation and review of Forms W-8BEN-E and W-8IMY.
- Structuring and Restructuring including determination of whether transactions qualify under IRC sections 368, 351, 332, and 355 and the interplay of IRC section 367.
- Determination of whether transactions of CFCs create Subpart F income (including applications of any available exceptions), computations of net Subpart F income and planning to avoid Subpart F income.
- Determination of whether transactions with CFCs creates an Investment in U.S. property under IRC section 956 and computation of the taxable income inclusion at the U.S. Shareholder level.
- Computations of earnings and profits for both foreign (including post-1986 foreign income tax pools) and domestic corporations (including domestic consolidated tax group’s E&P under Treas. Reg. section 1.1502-33).
- Computations of tax basis in the stock of CFCs and domestic corporations (including tax basis of stock of domestic corporation in U.S. consolidated tax group under Treas. Reg. section 1.1502-32).
- Planning and advising on IC-DISCs and calculations of commissions.
- Foreign cash repatriation planning including E&P loss planning and utilization of foreign tax credits and Previously Taxed Income.
- Inbound debt structuring and planning including analysis of judicial debt/equity factors and new IRC section 385 rules.
- Foreign acquisition and sale planning including elections under IRC section 338(g) in conjunction with foreign tax credit reductions under IRC section 901(m) and impact of such elections on the seller’s side (IRC section 1248 and foreign tax credit impact).
- Passive Foreign Investment Company analysis and calculations.
- Advice and computations related to foreign tax credits including creditability, income sourcing, limitation under IRC section 904, Overall Foreign Losses, Overall Domestic Losses, interest expense apportionment under the Fair Market Value method, etc.
- Assist in preparing and/or reviewing international components of the US Federal tax return including the Forms 5471, 8858, 8865, 5472 and 1118. Also, preparing and/or reviewing Forms 1042/1042-S and Treaty Based Returns on Forms 8833/1120-F.
- Application of Dual Consolidated Loss rules and preparation of various elections and annual certifications.
- 1-3 years of international tax experience, either in public accounting firm or law firm or combination of both required.
- Progress toward attaining CPA license or CPA license preferred; License to practice law preferred.
- Either a Masters in Taxation/Accounting or a Juris Doctor with an LL.M. in Taxation required, but an J.D./LL.M. in taxation is preferred.
- Strong analytical skills and broad understanding of U.S. corporate tax law with an emphasis in international corporate tax required