Tax - International Attorney in Livonia, MI

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Senior - International Tax The candidate will provide transactional support to quantify U.S. tax implications on various international transactions including mergers, acquisitions, dispositions, and liquidations of business units. Will review and prepare all aspects of U.S. tax compliance and reporting requirements including the computations of earnings and profits, Subpart F income inclusions, and other U.S. tax inclusions. Familiarity and knowledge of Form 5471 and Form 8858 is necessary. Review and prepare all aspects of foreign tax credit computations and the reporting of foreign source income and expense apportionment on Form 1118. Prepare and review of foreign partnership structures and U.S. tax reporting of foreign partnerships on Form 8865. Understanding of the U.S. tax rules and reporting requirements to review all necessary disclosure requirements attributable to international acquisitions, dispositions, and liquidations of business units. Prepare and oversee U.S. tax attributes to assist in U.S. tax reporting and international tax planning including earnings and profit pools, tax pools, tax basis in corporate and partnership structures, and foreign tax credits. Work with various outside tax advisers and law firms on special projects and international tax transactions including acquisitions, dispositions, or liquidations. Monitor budgets and quantify cost benefits for various projects are additional responsibilities. Assist in various repatriation strategies to return cash to the U.S. from various jurisdictions in a cash efficient manner. Responsible for quantifying and presenting tax return positions and results to upper management. Ability to communicate effectively and support business units in U.S. and international tax initiatives. Research and prepare tax memorandums of various international and U.S. tax issues. Responsible for responding to IRS IDR relating to U.S. and international tax issues. Assist in the international portion of the U.S. tax provision including local country tax provisions and ASC 740. Bachelor's degree in Accounting or Finance from an accredited institution is needed. Should have 7-10 years of overall tax experience (5 years in international compliance). Knowledge of CorpTax is preferred. Certified Public Accountant and/or Juris Doctor is preferred. Working with Word, Excel, and Power Point is required. Knowledge of Hyperion/HFM is required. Work well with others/team player.

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