Overview

Job Type:
Permanent

Primary Location:
Montreal, Quebec, Canada

All Available Locations:
Montreal

External Posting Description 13;

A career in Tax will offer you the opportunity to:

:Work in a fast growing and challenging environment with like:minded people who are eminent in their respective technical field;
:Develop solutions through debate and discussion, in our teams and with clients;
:Continue your professional development to reinforce and expand your chosen career path;
:Work with high profile clients on a variety of Canadian engagements.

As a Senior Manager you will:

:Plan and lead engagements including structuring corporate investment, developing acquisition strategies and tax compliance;
:Proactively take relevant and valuable tax ideas to our clients to grow the practice;
:Build relationships at a senior level and be seen as a trusted business advisor;
:Create a learning environment through leadership;
:Research (towards selecting form of entity) US inbound investments by corporations and/or partnerships;
:Assist in tax due diligence and modeling with respect to acquisition of US companies or Canadian companies with US subsidiaries or operations;
:Research whether under the United States : Canada Income Tax Convention (Treaty) the taxpayer has a permanent establishment within the United States;
:Research how various Treaty provisions (i.e., Business Profits, Personal Services, Capital Gains, Dividends, Interest, etc) affect the taxpayer;
:Review federal and multi:state corporate or partnership income tax returns including, where applicable, FinCEN 114, 5471, 5472 and other tax or informational forms;
:Where applicable review treaty protected tax returns under Internal Revenue Code (IRC) Section 6114;
:Review withholding tax returns including Forms 1042, 8804 and 8805;
:Determine whether taxpayer is a US Real Property Holding Company (USRPHC) and ensure that the provisions of Section 897 are accurately applied to the tax compliance process;
:Prepare debt equity models with respect to US inbound financing structures;
:Review tax computations including Sections 41 (Credits), 163 (Interest Stripping), 199 (Domestic Production Deduction), and 263A (UNICAP);
:Have basic understanding of transfer pricing tax considerations;
:Understand US state and local tax concepts including, but not limited to, water:edge election, nexus, PL 86:272, allocation and apportionment;
:Actively mentor and coach team members to their highest potential. 13;

External Posting Qualifications 13;

:Completed undergraduate degree with outstanding academic credentials;
:A completed Masters degree in Taxation or CPA or LLB; asset
:Minimum 7 years of relevant work experience, preferably in a Big Four;
:Experienced in business development and building a practice;
:References from former/current supervisors and/or clients;
:Superior verbal and written communication skills;
:Execute a client service plan on complex engagements and work closely with the Partners in exceeding our clients expectations while identifying and mitigating business risks associated with projects;
:Experienced with project problem diagnosis, solution development, client communications, facilitation of decision making, documentation, managing client expectations, project profitability and team leadership;
:Occasional Canadian travel required;
:Candidates must be able to enter the USA to work or attend tax technical courses. 13;

Get your career off to a great start. What impact will you make?

We’re always looking for people with the relentless energy to drive and push themselves further to find new avenues and unique ways of reaching our shared goals. At Deloitte, we know that being the undisputed leader means empowering our people to be the very best they can be : so they can make an impact that matters for clients, colleagues and the community, and for their own careers.

We offer a truly di


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