Tax Director, International - National Tax Office

We are seeking candidates with International Tax experience who are interested in providing tax and transfer pricing 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. 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. As a part of our National Tax Office, this practice is the Center of Excellence for all International Tax and Transfer Pricing projects.

Essential Functions and Primary Duties

• Provide US-outbound tax and transfer pricing planning support for international operations of US-headquartered companies, including repatriation strategies, foreign tax credit optimization, and local country tax planning opportunities

• 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

• Manage tax and transfer pricing engagements and oversee the projects from start to finish

• 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 and transfer pricing 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

• 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

• Support the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses.

Preferred Qualifications

• Master’s degree preferred in Accounting, Taxation or related field preferred

Minimum Qualifications

• Bachelor's degree required
• 8 years of experience in public accounting or related field
• 6 years of supervisory experience
• Must have active CPA or equivalent certification
• Ability to manage deadlines, work on multiple assignments and prioritize each assignment as necessary
• Proficient use of applicable technology
• Demonstrated ability to communicate verbally and in writing throughout all levels of organization, both internally and externally
• Proven high level of business integrity, client service and leadership skills
• Must be able to travel based on client and business needs