International Tax Director California

Full time
Based on Experience
california 18/02/2018   Full time Based on Experience




The Director, US International Tax, is responsible for the US international aspects of tax provisioning, compliance, controversy and planning for over 80 foreign entities. The role requires subject matter expertise in Subpart F, foreign tax credits, foreign currency, and M&A. 

Job Description:

  • Prepare/review quarterly and annual US international ASC 740 (FAS 109/FIN 48) tax accruals, inputs to global effective tax rate calculations and footnote disclosure
  • Prepare and/or review Forms 5471 for controlled foreign corporations
  • Prepare and/or review Forms 8858 and 8865 for flow through foreign entities
  • Prepare and maintain supporting documentation of earnings and profits pools, tax pools, PTI, and US tax basis for foreign subsidiaries and/or branches
  • Analyze and calculate taxable distributions, §78 gross-ups, §956 inclusions, §986(c) gains/losses, §987 gains/losses, Subpart F income, ECI, etc.
  • Support the preparation of Forms 1118 and 1116 for foreign tax credits and supporting documentation
  • Determine and maintain supporting documentation for §861 allocations to foreign source income
  • Prepare/review required elections and disclosures such as check-the-box elections, DCLs, etc.
  • Prepare/review and maintain tax basis balance sheets
  • Evaluate current processes and workflow, recommend and implement improvements
  • Assist in tax audits management and defense
  • Support M&A projects, including tax due diligence, review of tax sections in acquisition agreements, and post-acquisition integration/compliance
  • Provide US-outbound tax planning support for international operations including repatriation strategies, foreign tax credit optimization and local country tax planning opportunities.
  • Train, mentor and develop direct report(s)


  • Significant experience in financial reporting for international tax matters, including Subpart F, repatriation of foreign earnings, foreign tax credits and valuation allowance analysis.
  • Strong project management skills
  • People management experience
  • Resourcefulness and adaptability
  • Excellent communication (verbal and written) and financial analysis skills
  • Ability to explain complex tax concepts to non-tax stakeholders
  • Proficiency with Excel, CorpTax and SAP
  • 12-15 years of experience in public accounting and/or industry (industry experience preferred)
  • Bachelor’s degree or higher
  • JD/LLM, Masters in Taxation or CPA preferred