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Director, US International Tax Planning

🕒 3 days ago
US International Tax ProvisionsSubpart FNCTIBEAT

📜 Description

  • Lead and support US international tax planning projects from initial analysis through implementation.
  • Analyze the US international tax consequences of business initiatives, including new entities and jurisdictions.
  • Perform and review technical analysis under subpart F, NCTI, BEAT, and the foreign tax credit rules.
  • Apply subchapter C to entity formations, contributions, distributions, and internal reorganizations.
  • Define assumptions for models quantifying cash tax impacts and review for technical accuracy.
  • Support the M&A tax team by developing integration plans for acquired entities.

🛠️ Requirements

  • Deep technical knowledge of US international tax provisions, including subpart F, NCTI, BEAT, and foreign tax credit rules.
  • Working knowledge of subchapter C as it applies to multinational groups.
  • Experience leading tax planning projects end to end, including technical analysis and documentation.
  • Ability to research technical questions and write clear, supported memoranda.
  • Experience managing outside advisors and reviewing their output.

Benefits

  • Competitive compensation and benefits
  • Optional equity donation matching
  • Generous vacation and parental leave
  • Flexible working hours
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