Position Summary

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

Work You'll Do

Align global effective tax rate reduction and efficient global cash utilization with overall business strategy. Assist multinational clients with integrating tax planning into overall business strategy and complying with both U.S. and international regulatory requirements. Conduct technical review of international compliance workpapers and returns. Diagnose, solve, develop, and implement clients' tax needs. Direct complex tax research, formulate tax-planning strategies, and perform tax reviews. Advise U.S. and foreign multinational companies on the tax implications of their international operations. Coordinate U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy. Supervise assignments by Tax Consultants and Seniors and provide leadership, counseling, and career guidance. Will commute within the San Jose, CA area to consult with clients concerning the above job duties.

• Master's degree in Accounting, Finance, Taxation, Law, Business Administration, or related field (willing to accept foreign education equivalent).
• Three years as a Tax Manager or related occupation gaining experience performing international tax planning, U.S.-outbound tax reporting, and compliance for U.S. multinational corporations.
• Experience must include three years of:
  • Preparing work papers and international tax compliance forms and informational returns, including Forms 1120F, 5471, 5472, 8621, 8865, and 8858, disclosures and statements, and preparing federal tax compliance forms, including supporting schedules for Form 1065, including Schedules K-1 and K-3 disclosures and statements;
  • Advising clients on various international tax issues, including subpart F, global intangible low-taxed income (GILTI), overall foreign loss, and outbound transfers, and developing optimal tax structures for corporate restructuring, corporate reorganizations, and mergers and acquisitions;
  • Assisting with drafting tax memoranda to address tax technical analyses, including determining whether certain foreign entities' activities constitute a permanent establishment in the U.S. 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 and reviewing foreign-derived intangible income (FDII) calculations, interest expense allocation and effectively connected income (ECI) and fixed determinable and periodic (FDAP) income tax to estimate the U.S. income tax liability of 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.
• Less than 10% domestic travel outside normal commuting distance.
• Salary: $126,630.00 - $235,170.00/year.