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General Description: International tax senior 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. Therefore, the candidate must have good tax research and writing skills. Additionally, our International Tax group is very active in serving U.S. multinational companies in Charlotte market and the Carolinas. Therefore, in addition to having good tax research, writing and analytical skills, the candidate is also expected to have a basic understanding of accounting and tax computational and reporting/compliance 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.
- 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.
- Prepare and review technical tax memorandums including description of relevant facts, addressing of issue(s), adequate description of the relevant tax law, and logical analysis and conclusion.
- 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).
- 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 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.
- Application of Dual Consolidated Loss rules and preparation of various elections and annual certifications.
- At least two years of international tax experience required, either in public accounting firm or law firm or combination of both.
- CPA or license to practice law required
- Either a Masters in Taxation/Accounting or a Juris Doctor (preferably with an LL.M. in Taxation) required
- Strong analytical skills and broad understanding of U.S. corporate tax law with an emphasis in international corporate tax required