Position Summary
Deloitte Tax LLP seeks a Tax Senior Manager in San Jose, California
Work You'll Do
Align global effective tax rate reduction and efficient global cash utilization with overall business strategy. Oversee teams with assisting multinational clients with integrating tax planning into overall business strategy and complying with both U.S. and international regulatory requirements. Oversee teams 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. Oversee teams with assisting U.S. and foreign multinational companies on the tax implications of their international operations as well as coordinate U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy. Supervise assignments by Tax Consultants, Tax Seniors, and Tax Managers and provide leadership, counseling, and career guidance.
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Requirements
Master's degree in Accounting, Finance, Law, Business Administration or related field (willing to accept foreign education equivalent) plus four years of experience as a Tax Senior Manager or related occupation gaining experience performing tax planning, reporting and compliance for U.S. multinational corporations.
Experience must include four years of:
- Reviewing workpapers and international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8865, 8858, and 1118 disclosures and statements;
- Advising clients on various international tax issues, including subpart F, global intangible low-taxed income (GILTI), base erosion and anti-abuse tax (BEAT), overall foreign loss, and outbound transfers, and developing optimal tax structures for corporate restructuring, corporate reorganizations, and mergers and acquisitions;
- Assisting with drafting and reviewing tax memoranda to address tax technical analyses, including determining whether certain foreign entities' activities constitute a permanent establishment in the United States and what portion of income may be subject to U.S. federal income tax;
- Assisting with M&A integration structuring and planning for clients, and performing due diligence and analysis on U.S. tax consequences of integration step plan, including IP migration specialization and IP onshoring;
- Reviewing transaction documents and client data to identify contributions to foreign corporations in compliance with Form 926 requirements;
- Utilizing Corptax, LexisNexis, CCH, BNA, and RIA Checkpoint to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions;
- Analyzing workpapers to calculate foreign-derived intangible income (FDII), Section 861 deductions, 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 earnings and profits, foreign income inclusions, foreign tax credit analyses, and deferred tax asset utilization capacity analyses;
- Assisting audit teams in reviewing international tax-related calculations and disclosures, performing risk assessments, and preparing audit documentation; and
- Assisting with the full engagement lifecycle, including staffing, billing, and closing out projects.
Other
Hours: M-F, 40 hours/week;
Annual Salary: $156,904.00 - $249,480.00
If offered employment, must have legal right to work in U.S. EOE, including disability/veterans.
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Benefits
At Deloitte, we know that great people make a great organization. We value our people and offer employees a broad range of benefits. Learn more about what working at Deloitte can mean for you.
Our people and culture
Our inclusive culture empowers our people to be who they are, contribute their unique perspectives, and make a difference individually and collectively. It enables us to leverage different ideas and perspectives, and bring more creativity and innovation to help solve our clients' most complex challenges. This makes Deloitte one of the most rewarding places to work.
Our purpose
Deloitte's purpose is to make an impact that matters for our people, clients, and communities. At Deloitte, purpose is synonymous with how we work every day. It defines who we are. Our purpose comes through in our work with clients that enables impact and value in their organizations, as well as through our own investments, commitments, and actions across areas that help drive positive outcomes for our communities. Learn more.
Professional development
From entry-level employees to senior leaders, we believe there's always room to learn. We offer opportunities to build new skills, take on leadership opportunities and connect and grow through mentorship. From on-the-job learning experiences to formal development programs, our professionals have a variety of opportunities to continue to grow throughout their career.
As used in this posting, "Deloitte" means Deloitte Tax LLP, a subsidiary of Deloitte LLP. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.
All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability or protected veteran status, or any other legally protected basis, in accordance with applicable law.
Requisition code: 303102
Job ID 303102