Posted in Consultant 18 days ago.
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Location: Miami, Florida
Director, International Tax
Alvarez & Marsal Taxand, LLC is seeking a Director to join our International Tax practice. Our International Tax professionals work on a variety of international tax technical subjects including U.S. foreign tax credit and repatriation planning, cash management planning techniques, cross-border financing, treaty issues, accounting for income taxes, and total global effective tax rate management. Candidates must possess the experience, professionalism and leadership qualities necessary to deliver first-rate tax compliance and consulting services to meet our clients’ specific tax needs.
What will you be doing?
As a Director for the International Tax practice, you will 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. You will prepare and review quarterly and annual international ASC 740 (FAS 109/FIN 48) tax accruals, global effective tax rate calculations, and footnote disclosure. You will prepare and review Forms 5471 for controlled foreign corporations, Forms 8858 and 8865 for flow through foreign entities, Forms 1120, 1065 1120-S for U.S. companies with foreign operations, Form 1120-F for foreign corporations with U.S. trades or business/permanent establishments, and Forms 5472, 8804/8805, 1042/1042-S, 8828/8288-A/8288-B, etc. You will 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. Additionally, you will 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; and determine and maintain supporting documentation for §861 allocations to foreign source income.
You will be involved in preparing and reviewing required elections and disclosures such as check-the-box elections, DCL’s, etc., as well as maintaining tax basis balance sheets. You will 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. You will coordinate and assist clients with local reporting and filing requirements of foreign subsidiaries and foreign branches, determine PFIC status and prepare related computations, and assist in tax audits management and defense. You will organize and document restructuring and other planning initiatives including the preparation of power points slides, work plans or project timelines, technical memorandums, letters, opinions, and ruling requests. You will support the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses.
As a Director, you will coordinate with Taxand member firms to collect local tax returns and other information required to maintain global tax attributes of multinational clients. You will also 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, and mentor and supervise tax professionals.
Who will you be working with?
We are not a typical tax firm. We are a group of entrepreneurial, action-oriented and results-oriented tax professionals who take a hands-on approach to solving our clients’ problems and helping them reach their potential. We are nimble, resourceful, and proactive but adapt quickly when changes are needed. We present you with opportunities, not a playbook, and we reward you based on your achievements, not your tenure.
How will you grow and be supported?
As a demonstration of A&M’s strong commitment to its people, we offer benefits to support your career, personal and professional development. This includes an equity investment in a diversified financial services firm, the ability to invest in A&M private equity funds at beneficial terms, and a health and wellness program. Click to learn about our commitment to your well-being. A&M recognizes that our people fuel our growth, and you and your team will be provided with the best available training and development resources, as well as networking opportunities. Learn more about why A&M is a great place to work.
- 6+ years of international tax experience gained in public accounting
- Master’s Degree in Taxation or JD/LL.M preferred. Must be a Certified Public Accountant (CPA)
- 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
- Possess creative problem-solving skills
- Ability to work independently in an entrepreneurial environment
- Fluency in Spanish is a plus
It is Alvarez & Marsal’s policy to provide and promote equal opportunity in employment, compensation, and other terms and conditions of employment without discrimination because of race, color, sex, sexual orientation, family medical history or genetic information, political affiliation, military service, pregnancy, marital status, family status, religion, national origin, age or disability or any other non-merit based factor in accordance with all applicable laws and regulations.
Unsolicited Resumes from Third-Party Recruiters
Please note that as per A&M policy, we do not accept unsolicited resumes from third-party recruiters unless such recruiters were engaged to provide candidates for a specified opening. Any employment agency, person or entity that submits an unsolicited resume does so with the understanding that A&M will have the right to hire that applicant at its discretion without any fee owed to the submitting employment agency, person or entity.