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In-House
Attorney
Litigation - Whistleblower - CFTC
Tax
Min 6 yrs required
Manager – Tax The candidate will research (towards selecting form of entity) US inbound investments by corporations and/or partnerships. Will assist in tax due diligence and modeling with respect to acquisition of US companies or Canadian companies with US subsidiaries or operations. Research whether under the United States ‑ Canada Income Tax Convention (“Treatyâ€) the taxpayer has a permanent establishment within the United States. Research how various Treaty provisions (i.e., Business Profits, Personal Services, Capital Gains, Dividends, Interest, etc) affect the taxpayer. Review federal and multi-state corporate or partnership income tax returns including, where applicable, Forms 90-22.1, 5471, 5472 and other tax or informational forms. Where applicable review treaty protected tax returns under Internal Revenue Code (IRC) Section 6114. Review withholding tax returns including Forms 1042, 8804 and 8805. Determine whether taxpayer is a US Real Property Holding Company (USRPHC) and ensure that the provisions of Section 897 are accurately applied to the tax compliance process. Prepare debt equity models with respect to US inbound financing structures. Review tax computations including Sections 41 (Credits), 163 (Interest Stripping), 199 (Domestic Production Deduction), and 263A (UNICAP). Have basic understanding of transfer pricing tax considerations. Understand US state and local tax concepts including, water-edge election, nexus, PL 86-272, allocation and apportionment. Actively mentor and coach team members to their highest potential. Should have completed undergraduate degree with outstanding academic credentials. A completed Master’s degree in Taxation or CPA or LL.B. (LL.M. preferred) required. Should have 6+ years of relevant work experience, preferably big four.
Job ID: 3492225
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