Tax Manager

Tax | International Tax and Transfer Pricing

New York, New York, United States

Position Summary

Deloitte Tax LLP seeks a Tax Manager in New York, New York.

Work You’ll Do

Assist multinational clients with integrating tax planning into overall business strategy and complying with both U.S. and international regulatory requirements. Concentrate efforts on international compliance, research, consulting and planning issues. Diagnose, solve, develop, and implement clients' tax needs. Direct complex tax research, formulate tax-planning strategies, and perform tax reviews. Advise U.S. and foreign multinational companies on the tax implications of their international operations. Coordinate U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy. Supervise assignments by Tax Consultants and Tax Seniors and provide leadership, counseling, and career guidance.

Requirements

  • Master's degree in Accounting, Finance, Taxation, Law, or related field (willing to accept foreign education equivalent).
  • Three (3) years of experience as a Tax Manager or related occupation gaining experience performing tax planning, reporting and compliance in the financial services industry.
  • Experience must include one (1) year of:
    • Analyzing complex international tax issues, including Subpart F, global intangible low-taxed income (GILTI), Section 163(j), Section 338(g) elections, passive foreign investment company (PFIC) calculations, foreign-derived intangible income (FDII) calculations, base erosion and anti-abuse tax (BEAT), foreign tax credit (FTC), earnings and profits (E&P) adjustments, and previously taxed earnings and profits (PTEP), to assist client with both U.S. and cross-border strategies;
    • Utilizing tax tools, including partnership allocation and tiering software, to prepare and review partnership allocation workpapers and assist with compliance and consulting needs, including partnership tax allocations, K-1 aggregation, and generation, for hedge funds, private equity funds, and fund of funds clients in the financial services industry;
    • Performing controlled foreign corporation (CFC) analysis and passive foreign investment company (PFIC) testing to determine appropriate filing requirements and U.S. federal income tax consequences;
    • Analyzing work papers to calculate interest expense allocation and effectively connected income (ECI) to estimate the U.S. income tax liability of both U.S. and foreign corporations;
    • Reviewing client prepared work papers, including E&P and foreign income inclusions, and reviewing transaction documents and client data to identify contributions to foreign corporations in compliance with Form 926 requirements;
    • Preparing work papers and international tax compliance forms and informational returns, including Forms 1120F, 5471, 8621, 8865, and 8858 disclosures and statements, and preparing federal tax compliance forms, including Forms 1065, 8804, and 8805 disclosures and statements;
    • Utilizing tax software, including GoSystem, Corptax, LexisNexis, CCH, BNA, and RIA Checkpoint to prepare and review federal tax returns, research various U.S. federal income tax issues, and analyze tax rules and regulations of foreign jurisdictions;
    • Calculating gain/loss upon sale of investments, excess distribution, suspended loss, tax basis, and cash reconciliation;
    • Analyzing tax workpapers for tax adjustments in preparation of partnership schedule K-1s and tax returns; and
    • Performing engagement management support activities, including tracking project status and providing mentoring and coaching to junior staff.
  • Salary: $143,193.00 - $235,170.00/year
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Requisition code: 206434

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