Job Duties: Advise clients of the tax implications relating to their business objectives, recommend alternate courses of action, and identify different methods of complying with tax regulations with a focus on private equity, venture capital and alternative investments clients. Act as source for guidance on international tax questions and issues. Develop, recommend and implement practical international tax consulting-ideas related to private equity client situations. Ensure client service teams comply with firm policy regarding Written Tax Advice (WTA). Advise on deal structuring in relation to private equity, real estate and infrastructure investments. Identify and resolve complex taxation issues by applying multiple tax functional specialties. Work with U.S. and non-U.S. private equity funds on the following U.S. tax considerations: acquisition and disposition of U.S. and non-U.S. portfolio companies; analysis of passive foreign investment company (“PFIC”) and controlled foreign corporation (“CFC”) provisions specifically in relation to private equity and venture capital funds; U.S. investor considerations of fund-level and portfolio-level transactions including repatriation planning and exit considerations; withholding tax considerations of private equity and venture capital fund investments; general cross-border fund structuring from a U.S. tax perspective including tax efficient structuring of fund vehicles and fund management companies; and foreign information reporting of fund investments. Manage international tax services, including assessment of appropriate pricing structure for services. Manage client engagements and conduct detailed review of international tax aspects of U.S. tax reporting and other client supplied data and identify complex and advanced issues throughout the engagement. Represent clients before U.S. tax authorities on international tax aspects of contested issues. Supervises the day-to-day workload of International Tax, Senior Managers, Managers, Senior Associates, and Associates.Job Requirements: Master’s degree or foreign equivalent in Accounting, Laws, Taxation or related, plus one (1) year of experience in the job offered or as Senior Manager, International Tax or related. Alternatively, Employer will accept a Bachelor’s degree or foreign equivalent, in Accounting, Laws, Taxation or related plus five (5) years of progressively responsible experience.Must have experience in each of the following: Experience in corporate tax, international tax or legal professional services; Experience supervising tax professionals on a project or engagement basis; Experience with private equity and venture capital clients; Experience utilizing RIA, BNA, Lexis Nexis or Westlaw; and, Microsoft Office Suite, incl. Word, Excel and PowerPoint.Must have: CPA certification; OR Internal Revenue Service Enrolled Agent (“EA”) license; OR sufficient educational/experience requirements (as determined by state Board of Accountancy for CPA or by the Internal Revenue Service for EA) to receive CPA or EA within 24 months of hire or promotion; OR be a member of a US state bar.Employer will accept any suitable combination of education, training or experience.Rate of pay: $200,000 – $230,000 / year
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