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ProfileSeattle office of our client seeks mid-level international tax attorney with 5-6 years of experience. The candidate should have experience with international structuring and cross border transactions planning, management of complex and large multi-jurisdictional projects, and meaningful client responsibilities. Must possess strong technical and practical knowledge of U.S. and global international tax rules such as income sourcing rules, U.S. 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, U.S. and global transfer pricing documentation requirements, international aspects of U.S. tax reform, and other international tax topics. Familiarity with financial statements and models will be a plus. LL.M. degree in Tax is helpful.
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