Position Summary

Deloitte Tax LLP seeks a Tax Senior in Miami, FL.

Work You'll Do

Align global effective tax rate reduction and efficient global cash utilization with overall business strategy. Help multinational clients integrate tax planning into their overall business strategy and comply with both U.S. and international regulatory requirements. Assist companies with international compliance, research, consulting and planning issues. 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. Mentor and coach junior team members.

Requirements

• Bachelor's (or higher) degree in Finance, Accounting, Law, Business Administration, or related field (willing to accept foreign education equivalent).
• Eighteen months as Tax Senior or related occupation gaining experience performing tax planning, reporting and compliance for U.S. multinational corporations, partnerships, and high net worth individuals.
• Experience must include eighteen months of:
• Preparing international tax compliance forms and informational returns, including Forms 1118 and 5471, and Form 7004 disclosures and statements;
• Preparing federal tax compliance forms including Forms 1065 and 1120, Form 8804 disclosures and statements, and Schedules K-1, K-2 and K-3 for partner allocations;
• Preparing federal tax returns including Forms 1040, 1040NR, 1116 and 4868;
• Analyzing passive investments and nonpassive activities, including applying rental loss and passive loss limitations under IRC Section 469(e) and aggregating rental real estate activities under IRC Section 469(c)(7);
• Analyzing financial data to calculate Effectively Connected Income (ECI) to estimate the U.S.
• Income tax liability of foreign corporations and individuals under IRC Section 864(c), and analyzing Fixed, Determinable, Annual and Periodic (FDAP) income under IRC Sections 871 and 881;
• Advising clients on various international tax issues, including Subpart F under IRC Sections 951 through 965, Global Intangible Low-Taxed Income (GILTI) under IRC Section 951A, and Base Erosion and Anti-Abuse Tax (BEAT) under IRC Section 59A;
• Analyzing U.S. income tax treaties with foreign jurisdictions and analyzing the applicability of income tax treaty rates for interest and dividend income; and
• Utilizing CCH, BNA, and RIA Checkpoint to research various U.S. federal income tax issues, analyzing tax rules and regulations of foreign jurisdictions, and researching state tax regulations.