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Tax - International Attorney in San Francisco, CA

DLA Piper. Dec 12,2018 Jan 03,2018 Location USA San Francisco CA
This job is expired...

Law Firm

Attorney

Tax - International

5-6 yrs required

Profile

Mid-level International Tax Associate The candidate must have 5-6 years of experience at a law or accounting firm in international tax planning and consulting. An LL.M. in Tax would be helpful. Should preferably have experience with international structuring and cross border transactions planning, management of complex and large multi-jurisdictional projects, and meaningful client responsibilities. Must have strong technical and practical knowledge of US and global international tax rules such as income sourcing rules, US trade or business and effectively connected income, foreign tax credits, income tax treaty issues such as permanent establishment, income characterization, subpart F, withholding tax, tax-free organizations, IP migration and cost sharing arrangements, OECD BEPS actions, CbC reporting, key local OECD BEPS inspired legislation and related aspects such as UK DPT, UK anti-hybrid rules, and Australia MAAL, US and global transfer pricing documentation requirements, international aspects of US tax reform, and other international tax topics. Excellent analytical and writing skills are a must. Familiarity with financial statements and models will be a plus.

Additional info

Ref. #: 17000866

Company info