Assist the Director, International Tax Compliance to prepare and file corporate income tax returns. The primary focus will be preparing non-U.S. tax compliance for U.S. Federal income taxreporting.
Assist in all non-U.S. income tax analysis including foreign tax credits, earnings & profits, and currency gains & losses. The role is the focal liaison point between the various U.S. and non-U.S. Accounting COE groups, and the Tax COE.
- Prepare Form 5471 for controlled foreign corporations and Form 8858 for foreign disregarded entities and Form 8865 for foreign partnerships for annual consolidated tax filings.
- Assist with preparation of Form 1118 and document all requiredsupport for this filing.
- Assist in the Calculation §987 gains & losses and §861 allocations to foreign source income.
- Prepare and monitor earnings and profits pool for all non-U.S. affiliates.
- Prepare and monitor income tax paid pool for all non-U.S. affiliates.
- Quantify amount of Subpart F income for U.S. quarterly and annual U.S. taxreporting for effective tax rate calculations purposes.
- Prepare required elections and disclosures such as check-the-box elections.
- Assist with ASC 740 tax accounting for non-U.S. affiliate reporting.
- Assist with technical modelling support and analysis for tax planning on acquisitions, restructurings and other strategic projects (i.e., foreign dividend planning and cash re-deployment, what-ifs, gain/loss calculations, §367, §382, §338) to determine U.S. tax, foreign tax and business implications.
- Work closely with the Treasury function to help analyze and manage all intercompany transactions, cash pooling methodologies, foreign exchange issues, and cash tax benefits from tax planning.
- Assist with monitoring and tracking international cash tax payments and forecasting.
- Develop relationships with financial personnel in each foreign jurisdiction to ensure information is timely and accurately provided for U.S. income tax compliance and strategic planning purposes.
- Coordinate filing activities for various Hertz subsidiaries in non-U.S. & non-European jurisdictions.
- Assist and monitor tax and finance structuring including capitalization/debt financing of non-U.S. operations.
- Review Tax Return and ASC 740 calculations for foreign subsidiaries in Canada, Puerto Rico, Australia, and New Zealand.
- Refine and implement company’s data collection package from all subsidiaries.
- Assist the tax planning group in all cash planning efforts and any transaction analysis including reviewing tax basis calculations and providing sub F and or other taxable income impacts of proposed or executed transactions
- Assist Director, International Tax Compliance on Special projects as necessary
- Perform the role of CorpTax Software Administrator
- Masters’ Degree in Taxation preferred
- Minimum 5 years of international taxexperience with a preference toward a mix of public accounting and global private industry experience.
- Preparation of Forms 5471, 8858 & 8865.
- Understanding of earnings and profits and experience with maintaining E&P and tax pools.
- Ability to develop global business acumen and a working knowledge of the tax rules for most of the major foreign countries in North America, Europe, Asia and Latin America.
- Knowledge using CorpTax tax return software is required.
- Be an active learner that is detail oriented and a proven self-starter with the ability to multitask, prioritize responsibilities and complete work timely and accurately.
- Excellent communication skills (oral and written) and the ability to professionally represent the tax department when interacting with other functions in the Company and with outside advisors.
- Strong problem solving, organizational and time management skills to complete multiple assignments on a timely basis.
- Strong process management and documentation skills.
- Proficient with Excel and other Microsoft office products.
- Ability to work effectively across a complex organization and with external third parties