Job Details

International Tax Director

Company name

Alvarez & Marsal Holdings, LLC.

Organization Type

In-House

Job Type

Attorney

Valid Through

Nov 26,2019

Posted on

Aug 13,2019

Years of Experience

5-8 yrs required

Location

Miami, FL, United States

Employment Type

Full-time

Industry

Legal
Practice Area
Tax >> Tax - International
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International Tax Director
Responsibilities: Provide US-outbound tax planning support for international operations of US-headquartered companies, including repatriation strategies, foreign tax credit optimization and local country tax planning opportunities. Prepare/review quarterly and annual international ASC 740 (FAS 109/FIN 48) tax accruals, global effective tax rate calculations, and footnote disclosure. Prepare/review Forms 5471 for controlled foreign corporations. Prepare/review Forms 8858 and 8865 for flow through foreign entities. Prepare/review Forms 1120, 1065, 1120-S for U.S. companies with foreign operations. Prepare/review Form 1120-F for foreign corporation with U.S. trades or business/permanent establishments. Review Forms 5472, 8804/8805, 1042/1042-S, 8828/8288-A/8288-B, etc. Prepare/review and assist in maintaining supporting documentation of earnings and profits pool, tax pool, PTI, and US tax basis for foreign subsidiaries and/or branches of US multinationals. Analyze and calculate taxable distributions, §987 gains/losses, Subpart F income, ECI, Global Intangible Low Taxed Income, CFC attribution, Section 245A Deduction, hybrid transactions, 163(j), FDII, etc. Support the preparation of Forms 1118 and 1116 for foreign tax credits and supporting documentation. Determine and maintain supporting documentation for §861 allocations to foreign source income. Prepare/review required elections and disclosures such as check-the-box elections, DCL’s, etc. Prepare/review and maintain tax basis balance sheets. Assist in the design and review of intercompany pricing policies for clients on products and services, and work with the transfer pricing group to review transfer pricing reports, and related compliance filings. Coordinate and assist clients with local reporting and filing requirements of foreign subsidiaries and foreign branches. Determine PFIC status and prepare related computations. Assist in tax audits management and defense. Organize and document restructuring and other planning initiatives including the preparation of power points slides, work plans or project time lines, technical memorandums, letters, opinions and ruling requests. Support the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses. Coordinate with Taxand member firms to collect local tax returns and other information required to maintain global tax attributes of multinational clients. Coordinate with Taxand member firms regarding non-US tax matters and local country planning. Develop new business with existing clients and potential targets. Deliver proposals and other client presentations. Provide and review written and oral advice to clients serving a range of industries. Mentor and supervise tax professionals.

Qualification and Experience

The candidate should have Master’s Degree in Taxation or JD/LL.M preferred. Must be a Certified Public Accountant (CPA). Should have 5-8+ years international tax experience gained in public accounting, industry and/or law firm. Strong U.S. tax compliance experience required. Leadership skills and the ability to exceed client expectations and deliver quality client service. Demonstrated ability to develop new business. Ability to collaborate with others. Excellent research, writing and oral communication skills. Strong project management skills. Willingness to travel. Possess creative problem-solving skills. Ability to work independently in an entrepreneurial environment. Fluency in Spanish is a plus.

Company info

Hiring Coordinator
Alvarez & Marsal Holdings, LLC.
600 Brickell Avenue
Suite 2950
Miami, FL 33131

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