Deloitte US

Deloitte Tax LLP seeks a Tax Senior in Boston, Massachusetts.

Work You’ll Do
Conduct research on tax implications and analyze tax rules and regulations to ensure compliance requirements are met for U.S. and foreign multinational companies. Review international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8865 and 8858 disclosures and statements prepared by junior team members. Assist with auditing client prepared work papers, including Global Intangible Low-Taxed Income, Subpart F and foreign tax credit. Assist with Section 987 pre-transition gains and losses, ensuring accurate reporting and compliance with IRS regulations. Assist with Pillar two Transitional Country-by-Country Reporting Safe Harbour and GloBE calculations to determine the appropriate tax liabilities and ensure compliance with international tax standards. Identify and communicate issues that require the immediate attention of senior members of the engagement team. Mentor and coach junior team members. Assist with program activities for engagements by ensuring the completeness of work plans and maintaining clear communication with team members and clients to meet project milestones and adhere to client deadlines. Will commute within the Boston, MA area to consult with clients concerning the above duties.

Requirements
Bachelor's (or higher) degree in Finance, Accounting, Law, Business Administration, or related field (willing to accept foreign education equivalent) plus eighteen months of experience as a Tax Senior or related occupation gaining experience performing tax planning, reporting and compliance for U.S. multinational corporations. Experience must include eighteen months of:
--preparing international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8865 and 8858 disclosures and statements;
--analyzing work papers to calculate Section 861 deductions, interest expense allocation and effectively connected income (ECI) to estimate the U.S. income tax liability of foreign corporations;
--assisting with advising clients on various international tax issues including Subpart F, overall foreign loss, outbound transfer and inversions, and developing optimal tax structures for corporate restructuring, corporate reorganization, mergers and acquisitions;
--conducting research and preparing materials for consulting projects focused on tax planning considerations, including the development of transaction step plans, and tax memos;
--researching and analyzing client information to determine whether certain foreign entities' activities constitute a permanent establishment in the U.S. and what portion of income may be subject to U.S. federal income tax;
--performing passive foreign investment company (PFIC) analysis and testing to determine appropriate filing requirements and U.S. federal income tax consequences;
--reviewing proposed merger and acquisition transactions, and other relevant transactions and client data to identify contributions to foreign corporations and comply with Form 926 requirements;
--utilizing CCH and BNA to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions; and
--auditing client prepared work papers involving Global Intangible Low-Taxed Income (GILTI), Subpart F, and foreign tax credit analysis.
Less than 10% domestic travel outside normal commuting distance.

Other
Annual Salary: $94,500.00 - $175,500.00.