Deloitte Tax LLP seeks a Tax Senior in San Jose, CA.
Work You’ll Do
Align global effective tax rate reduction and efficient global cash utilization with overall business strategy. Help multinational clients integrate tax planning into their overall business strategy and comply with both U.S. and international regulatory requirements. Assist companies with international compliance, research, consulting and planning issues. Advise U.S. and foreign multinational companies on the tax implications of their international operations. Prepare and review analyses of Controlled Foreign Corporation (CFC) and Passive Foreign Investment Company (PFIC) asset testing and determine related tax implications. Coordinate U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy. Mentor and coach junior team members.
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Requirements
- Bachelor's (or higher) degree in Finance, Accounting, Law, Business Administration, or related field (willing to accept foreign education equivalent).
- Eighteen months of tax compliance, planning, and research experience.
- Experience must include one year of:
- Preparing international tax compliance forms, including Form 5471, 8858, 8865, 8992, 8993, 1118, and 8621, and E&P, Subpart F and GILTI inclusion analyses;
- Reviewing U.S. and foreign partnership tax returns and related forms, including Form 1065, Form 8865 and Schedule K-1;
- Researching and analyzing international tax regulations, and providing analysis to client regarding compliance with U.S. tax regulations;
- Assisting multinational clients to integrate tax planning into their overall business strategy and to comply with both U.S. and international regulatory requirements;
- Performing controlled foreign corporation (CFC) and passive foreign investment company (PFIC) analysis to determine appropriate filing requirements and U.S. federal income tax consequences;
- Utilizing CCH, BNA and RIA Checkpoint to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions;
- Calculating U.S. taxable income of foreign corporations in fund-of-funds investment structures, including aggregating effectively connected income (ECI) amounts from partnership K-1s, calculating branch profits tax and Section 705 partnership basis amounts, and apportioning interest expense under Treas. Reg. § 1.882-5;
- Assisting with research on various international tax issues including subpart F, expenses allocation and apportionment, outbound transfers of U.S. property and inversions, optimal tax structuring for corporations, corporate reorganizations, and U.S. permanent establishments;
- Reviewing and researching compliance with Form 926 requirements; and
- Auditing annual accrual of accounting and reviewing foreign data to calculate income taxes on foreign operations in support of Accounting Standards Codification (ASC) 740-10 positions, including addressing ASC 740-30 assertions and ASC 830-10 functional currency issues.
Salary: $92,498.00 - $161,200.00/year;