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Tax Counsel
Refer job# PHJM144775
 
Tax Counsel The candidate responsibilities will include capital and legal entity structuring, mergers and acquisitions, joint ventures and dispositions. Will be responsible for reviewing and handling a broad spectrum of U.S. tax planning issues for the ongoing operations of the businesses depending on the needs of the department. Will be responsible for coordinating advice and strategies with other members of the global tax and customs function. Tax planning entails issue identification, development of alternative solutions, recommendation to business unit and functions, assistance with implementation, and (if necessary) post-implementation review. Play a key role in the companys strategic tax planning and initiate and implement high value tax strategies. Identify opportunities to optimize the companys foreign tax position, while coordinating with US tax issues. Facilitate and manage the tax forecasting process, including multi-year planning. Manage and communicate forecasting scenarios based on business needs and requests from senior leadership. Work closely with peers group to monitor legislative and regulatory developments, as well as company initiatives, and incorporate into forecasting process. Partner and influence other leaders within firm's Global Tax to build and maintain an effective tax infrastructure. Manage relationships with clients and business associates. Provide tax planning and tax research consulting services. Assist with development of legal arguments and management of external resources in connection with audits and litigation. Partner with local country finance teams on foreign audits to resolve foreign tax controversies. Foster continuous improvement, technical expertise, and best practices and processes. Provide legal advice to the U.S. tax compliance groups regarding reporting issues and also to US GAAP tax accounting group. Provide training to business units and functions on key tax initiatives and policies.

The candidate must possess a Juris Doctor. Should have 5+ years of tax planning experience with a major law firm or Big Four public accounting firm. Must have experience demonstrating a practical and technical understanding of the U.S. tax rules applicable to business transactions and mergers, acquisitions, and dispositions. Should have ability to identify and resolve tax issues with limited input from senior team members or third party advisors. Must have writing skills acquired through legal training as well as work on I.R.S. rulings, appeals and/or litigation or foreign controversies. Should preferably have experience in one or more of the following tax sub-specialties: taxation of partnerships, financial products, international tax (BEAT, GLTI, Subpart F)income tax accounting and tax procedure. Must have JD degree with honors from top-25 law school. MBA or other degree in quantitative area will be highly desired (e.g., mathematics, economics, or finance).
 
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