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Tax Managing Director | Transfer Pricing - National Tax Office

CBIZ
San Francisco, CA Full Time
POSTED ON 1/24/2025
AVAILABLE BEFORE 4/23/2025

CBIZ, Inc. is a leading professional services advisor to middle market businesses and organizations nationwide. With unmatched industry knowledge and expertise in accounting, tax, advisory, benefits, insurance, and technology, CBIZ delivers forward-thinking insights and actionable solutions to help clients anticipate what's next and discover new ways to accelerate growth. CBIZ has more than 10,000 team members across more than 160 locations in 21 major markets coast to coast. CBIZ strives to be our team members’ employer of choice by creating an environment where team members are appreciated, recognized for their contributions, and provided with opportunities to grow, both personally and professionally, throughout their careers. Together, CBIZ and CBIZ CPAs are ranked as one of the top providers of accounting services in the United States. CBIZ CPAs is an independent CPA firm that provides audit, review and attest services, while CBIZ provides business consulting, tax and financial services. In certain jurisdictions, CBIZ CPAs operates under its previous name, Mayer Hoffman McCann P.C.We are seeking candidates with Transfer Pricing 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 DutiesDemonstrate proactive client contact; viewed as a trusted business partnerExpand business practice; cultivate new clients; increase services to existing clients including cross serving opportunitiesProvide 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 opportunitiesAssist 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 filingsManage tax and transfer pricing engagements and oversee the projects from start to finishCoordinate 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 defenseOrganize 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 requestsPrepare and review quarterly and annual international ASC 740 (FAS 109 / FIN 48) tax accruals, global effective tax rate calculations, and footnote disclosurePrepare 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 multinationalsAnalyze and calculate taxable distributions987 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 sheetsSupport the preparation of FATCA, FBAR or other related forms and other international information requirements for individuals and businesses.Minimum Qualifications RequiredBachelor’s degree required; Master’s degree preferred in Accounting, Taxation or related field preferred10 years of experience in public accounting or related field10 years supervisory experienceMust have active CPA or equivalent certificationAbility to manage deadlines, work on multiple assignments and prioritize each assignment as necessaryProficient use of applicable technologyDemonstrated ability to communicate verbally and in writing throughout all levels of organization, both internally and externallyProven high level of business integrity, client service and leadership skillsMust be able to travel based on client and business needsThe annual salary target for this job in this market is $300,000-$550,000 The specific compensation for this role will be determined based on the education, experience, and skill set of the individual selected for this position.The compensation above is not representative of an employee’s total compensation. Beyond income, you have access to : comprehensive medical and dental insurance, retirement savings, life and disability insurance, health care and dependent care reimbursement accounts, certification incentives, education assistance, referral program and much more.#LI-TV1#LI-Hybrid

Salary : $300,000 - $550,000

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