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Tax - International Attorney in Charlotte, NC

Dixon Hughes Goodman, LLP Jun 28,2017 Apr 18,2017 Location USA Charlotte NC
This job is expired...

In-House

Attorney

Tax - International

2-5 yrs required

Profile

International Tax Senior Associate The candidate will 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. Structure and restructure including determination of whether transactions qualify under IRC sections 368, 351, 332, and 355 and the interplay of IRC section 367. Determine 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. Determine 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. Computation 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). Computation 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). Plan and advise 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. 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. 2 – 5 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 required; License to practice law preferred. Strong analytical skills and broad understanding of U.S. corporate tax law with an emphasis in international corporate tax required.

Additional info

Job ID: 3607BR

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