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transfer pricing asc 740 gilti foreign tax credits subpart fπ Description
- Lead U.S. international tax planning and structuring (M&A, cross-border, expansion)
- Own U.S. international tax provision calculations under ASC 740 (GILTI, credits)
- Lead U.S. international tax compliance and reporting (5471/8858/8991-8993/1118)
- Manage intercompany transactions and global transfer pricing policies
- Monitor global tax developments; model impacts; advise leadership
- Support repatriation planning and international tax initiatives
π― Requirements
- 6+ years of U.S. international tax experience (Big 4 and/or in-house)
- Demonstrated experience applying ASC 740 and U.S. international tax rules (GILTI, Subpart F, transfer pricing)
- Experience preparing or reviewing U.S. international information returns (Forms 5471 and 8858)
- Experience preparing or reviewing international components of quarterly and annual tax provisions
- Pillar Two modeling, readiness, or implementation (nice to have)
- SaaS/tech or high-growth company experience (nice to have)
- Public company experience (nice to have)
- Masterβs in Taxation, CPA license, JD, or LLM (nice to have)
π Benefits
- Equity for employees
- Health, dental, and vision coverage
- Retirement plan with company contribution
- Parental leave and family planning support
- Mental health and wellness benefits
- Generous PTO and recharge days
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