Job Description:

- Manage income tax preparation engagements and work in the business tax group.

- Proven experience working with multinational businesses operating in the US, with a strong understanding of how US tax and accounting regulations differ from those in other countries.

- Be familiar with US international tax concepts, rules, and requirements relating to multinational business operations, including items such as transfer pricing, inbound inversions, and income inclusion related to CFCs.

- Able to provide advice on numerous issues that relate to doing business in the US, such as discussions around retirement plans, payroll setup, sales tax, accounting requirements and obligations compared to other countries.

- Able to spot and advise on cross border issues that may not be appropriately addressed by clients and respectfully raise issues proactively with clients.

- Have familiarity with the US Tax Treaties and related concepts such as permanent establishment, ECI, FDAP, and withholding tax obligations for foreign companies and individuals.

- Demonstrate ability to research complex tax situations involving multi-entity international controlled group structures.

- Understands the required technical reporting on tax returns including those related to Forms 114, 5471, 5472, 8858, 8865, and 8938.

- Experience with various elections and disclosures relating to Form 3115, Form 8832, Sec. 351, Sec. 361, Sec. 451, and Sec. 6038.

- Able to perform calculations related to various international tax concepts including PFICs, foreign tax credit limitations, section 956 inclusions, FDII deductions, and GILTI and subpart F income allocations.

- Be familiar with domestic tax issues such as state nexus, 382 limitations, deferred compensation, deferred revenue, UNICAP, 163(j) limitations, and R&D capitalization.

- Ability to work with legal and foreign advisors to come up with mutually agreed upon business plans and structures.

- Willingness to immediately take on a small book of clients and provide top notch client service.

- Desire to be growth oriented and grow the book of business over time.

- Willing to work closely with a lead partner and a select group of professional staff.

- Duties will include high level review of various tax submissions, as well as tax consulting.

Key Skills:

- Leadership

- Form 1065

- Real Estate

- Partnership Tax

- Taxation