Our client a specialist firm of accountants in the music sector who are seeking to recruit an International Corporate Tax Manager/Senior Manager with US Corporate Tax experience. The client is considering candidates with US Corporate Tax experience from any sector looking to specialise in the music sector. The firm has offices in the UK, US, Sweden and the Netherlands and offers the potential for a secondment to the US office at some stage if so desired.
Responsibilities
- Advise clients on US federal corporate tax issues on US inbound and outbound investments, restructuring, mergers and acquisitions, tax treaties, withholding tax, foreign tax credit and other international tax issues related to U.S. tax
- Perform strategic tax analyses and cash flow models to calculate earnings, profits and basis in order to determine potential US federal and state income tax consequences * Determine US controlled foreign corporation ("CFC") and/or passive foreign investment company ("PFIC") status plus Global Intangible Low-Taxed Income (GILTI) issues
- Write opinions/advice on tax refund claims, including reclaim of excess withholding tax related to 1042-S withholding certificates
- Advise on range of US corporate tax issues, including character of income, Permanent Establishment, Entity Classification Election and related check-the-box implications
- Write, review and provide tax comfort letters on US tax disclosures, green card relinquishment considerations and treaty positions
- Perform vendor or target US corporate tax due diligence related to mergers and acquisitions
- Determine Foreign Account Tax Compliance Act ("FATCA") status of non-US entities and assist with their reporting requirements
- Prepare and review foreign reporting forms for federal purposes including Forms 5471, 5472, 926, 8865, 8858, 8832, FBARs (and Forms 3520 and 3520-A though this isn't essential) plus relevant corporate state filings
- Consider U.S. tax implications of financial reporting (including financial statement disclosures related to tax), calculation of tax provisions and quarterly tax payments
Candidate Requirements
- 7+ years of experience in U.S. federal and state income tax compliance for global clients, federal and state income tax accounting and provisions, tax analysis, and tax research with experience advising corporations on cross-border US tax issues and developing tax-efficient structures tailored to specific client needs
- Masters in Taxation or Bachelor's degree in Accounting, Finance, Tax or other business-related major * Experience with Big 4, public accounting, or consulting
- Licensed CPA, Licensed Attorney, Enrolled Agent, or other tax certification
- Solid understanding and experience of accounting for income taxes in accordance with ASC 740, Tax Accounting and Provisions Services.
Please apply on-line for immediate consideration. Once you have applied if you have any questions call 0203 22 55 060.
Please also note that due to the volume of applications, only those shortlisted will be contacted. If you have not received a response within two weeks, please assume your application for this role was unsuccessful.
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