International Tax Senior Manager

Company: CBIZ, Inc.
Location: Boston
Posted on: June 13, 2021

Job Description:

With over 100 offices and nearly 5,000 associates throughout the U.S. CBIZ (NYSE: CBZ) delivers top-level tax compliance, consulting and co-sourcing services to Private Equity firms of all sizes, by providing national-caliber expertise combined with highly personalized service.

CBIZ has been honored to be the recipient of several national recognitions:

• 2020 Best Workplaces in Consulting & Professional Services by Great Place to Work
• 2020 Workplace Excellence Seal of Approval by the Alliance for Workplace Excellence
• Top 101 2020 Best and Brightest Companies to Work For in the Nation
• 2020 Healthiest 100 Workplace in America
• 2021 Top Workplaces USA

Together, CBIZ and Mayer Hoffman McCann P.C. (MHM) are ranked as one of the top providers of accounting services in the United States. MHM is an independent CPA firm that provides audit, review and attest services, while CBIZ provides, business consulting, tax and financial services.

CBIZ & MHM New England is part of the 10th largest accounting*, tax, and advisory services provider in the nation. Our two New England offices are located in Boston and Providence and have over 240 people, including over 40 Managing Directors. We uniquely combine national resources with local decision-making by experienced, New England-based professionals who are dedicated to strengthening our clients' financial positions.

We are seeking candidates with International Tax experience who are interested in providing their tax services for International operations with US-headquartered companies. The opportunity will include working with CBIZ team members and client personnel virtually or at the client location when the conditions are safe. We offer an opportunity to work on rewarding, high profile clients with exposure to interesting technical matters using a team approach that allows for great work life balance in a friendly, supportive environment.

Essential Functions and Primary Duties

• Provide US-outbound tax planning support for international operations of US-headquartered companies, including repatriation strategies, foreign tax credit optimization, and local country tax planning opportunities
• Prepare and review quarterly and annual international ASC 740 (FAS 109/FIN 48) tax accruals, global effective tax rate calculations, and footnote disclosure
• Prepare and review Forms 5471 for controlled foreign corporations, Forms 8858 and 8865 for flow through foreign entities, Forms 1120, 1065 1120-S for U.S. companies with foreign operations, Form 1120-F for foreign corporations with U.S. trades or business/permanent establishments, and Forms 5472, 8804/8805, 1042/1042-S, 8828/8288-A/8288-B, etc.
• Prepare, review and assist in maintaining supporting documentation of earnings and profits pool, tax pool, PTI, and US tax basis for foreign subsidiaries and/or branches of US multinationals
• Analyze and calculate taxable distributions
• 987 gains/losses, Subpart F income, ECI, Global Intangible Low Taxed Income, CFC attribution, Section 245A Deduction, hybrid transactions, 163(j), FDII, etc; support the preparation of Forms 1118 and 1116 for foreign tax credits and supporting documentation; and determine and maintain supporting documentation for 861 allocations to foreign source income.
• Prepare and review required elections and disclosures such as check-the-box elections, DCL's, etc., as well as maintaining tax basis balance sheets
• Assist in the design and review of intercompany pricing policies for clients on products and services, and work with the transfer pricing group to review transfer pricing reports and related compliance filings
• Coordinate and assist clients with local reporting and filing requirements of foreign subsidiaries and foreign branches, determine PFIC status and prepare related computations, and assist in tax audits management and defense
• Organize and document restructuring and other planning initiatives including the preparation of power points slides, work plans or project timelines, technical memorandums, letters, opinions, and ruling requests
• Support the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses.

Preferred Qualifications

• Master's degree in Accounting, Taxation or JD/LL.M. preferred
• Excellent research, writing and oral communication skills
• Ability to work independently in an entrepreneurial environment

Minimum Qualifications

• Bachelor's degree required
• 8 years of international tax experience in public accounting or related field
• 6 years of supervisory experience
• Must have active CPA or equivalent certification

Keywords: CBIZ, Inc., Boston , International Tax Senior Manager, Other , Boston, Massachusetts