Tax Job Info Sharing: Deloitte Experienced Hire

Manager in Canada for US Taxes – located Vancouver (Tax)


Manager U.S Tax ‑ Canada

 
A career in Tax will offer you the opportunity to:

• Work in a fast growing and challenging environment with like-minded people who are eminent in their respective technical field
• Develop solutions through debate and discussion, in our teams and with clients
• Continue your professional development to reinforce and expand your chosen career path
• Work with high profile clients on a variety of Canadian and international engagements

As a Manager you will:

• Research (towards selecting form of entity) US inbound investments by corporations and/or partnerships.
• Assist in tax due diligence and modeling with respect to acquisition of US companies or Canadian companies with US subsidiaries or operations.
• Research whether under the United States ‑ Canada Income Tax Convention (“Treaty”) the taxpayer has a permanent establishment within the United States.
• Research how various Treaty provisions (i.e., Business Profits, Personal Services, Capital Gains, Dividends, Interest, etc) affect the taxpayer.
• Review federal and multi-state corporate or partnership income tax returns including, where applicable, Forms 90-22.1, 5471, 5472 and other tax or informational forms.
• Where applicable review treaty protected tax returns under Internal Revenue Code (IRC) Section 6114.
• Review withholding tax returns including Forms 1042, 8804 and 8805.
• Determine whether taxpayer is a US Real Property Holding Company (USRPHC) and ensure that the provisions of Section 897 are accurately applied to the tax compliance process.
• Prepare debt equity models with respect to US inbound financing structures.
• Review tax computations including Sections 41 (Credits), 163 (Interest Stripping), 199 (Domestic Production Deduction), and 263A (UNICAP).
• Have basic understanding of transfer pricing tax considerations.
• Understand US state and local tax concepts including, but not limited to, water-edge election, nexus, PL 86-272, allocation and apportionment.
• Actively mentor and coach team members to their highest potential.

Qualifications:

• Completed undergraduate degree with outstanding academic credentials
• A completed masters degree in Taxation or CPA or LLB (LLM preferred)
• Minimum 6 years of relevant work experience, preferably big four.
• References from former/current supervisors and/or clients.
• Superior verbal and written communication skills
• Occasional Canadian travel required
• Candidates must be able to enter the USA to work or attend tax technical courses.

Deloitte is one of the leading professional services organizations in the United States, specializing in audit, tax, consulting, and financial advisory services with clients in more than 20 industries. We provide powerful business solutions to some of the world’s most well-known and respected companies, including more than 75 percent of the Fortune 100.

At Deloitte, you can have a rewarding career on every level. In addition to challenging and meaningful work, you’ll have the chance to give back to your community, make a positive impact on the environment, participate in a range of diversity and inclusion initiatives, and find the support, coaching, and training it takes to advance your career. Our commitment to individual choice lets you customize aspects of your career path, your educational opportunities and your benefits. And our culture of innovation means your ideas on how to improve our business and your clients’ will be heard.

About Deloitte

As used in this document, “Deloitte” means Deloitte LLP and its subsidiaries. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, disability or protected veteran status, or any other legally protected basis, in accordance with applicable law.

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