Deloitte Tax LLP seeks a Tax Manager in San Jose, CA.

Work You’ll Do

Align global effective tax rate reduction and efficient global cash utilization with overall business strategy. Help multinational clients integrate tax planning into their overall business strategy and comply with both U.S. and international regulatory requirements. Assist companies with international compliance, research, consulting and planning issues. Help companies understand national, state and local, and international tax structures and align the tax function with business objectives. Coordinate U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy. Analyze international tax issues when a company is engaged in a merger or acquisition, maintaining compliance with multi-jurisdictional business transactions, or streamlining multi-national supply chain. Mentor and coach junior team members.

Requirements

• Bachelor's (or higher) degree in Accounting, Finance, Law, Business Administration, or related field (willing to accept foreign education equivalent, including a 3-year foreign degree).
• Four years as a Tax Manager or related occupation gaining experience performing tax planning, reporting and compliance for multinational corporations.
• Experience must include three years of:
  • Preparing work papers and international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8865, 8858, and 1118 disclosures and statements, and preparing federal tax compliance forms, including Forms 1065, 8804, and 8805 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;
  • Performing analysis of Section 338(g) and asset allocation workbooks for Form 8883, and preparing Form SS-4 to obtain EIN, Form 8802 to obtain U.S. tax residency certificate, and Form 8832 for entity classification election;
  • Assisting with drafting 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;
  • Performing controlled foreign corporation (CFC) analysis and passive foreign investment company (PFIC) testing to determine appropriate filing requirements and U.S. federal income tax consequences;
  • Reviewing transaction documents and client data to identify contributions to foreign corporations in compliance with Form 926 requirements;
  • Utilizing LexisNexis, CCH, and BNA to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions;
  • Analyzing work papers 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; and
  • Assisting audit teams in reviewing international tax-related calculations and disclosures, performing risk assessments, and preparing audit documentation.
• Salary: $137,030.00 - $235,170.00/year.