International Tax Manager


Company:: Morgan Stanley
(View company profile)
Location:: New York City, NY
Job Type:: Full Time
Category:: Investment Banking

Yrs of Exp:: 2+ to 5 years
Posted:: 1/9/2013

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Job Description

Position Category: Finance/Accounting

Position Title: International Tax Manager

Job Level: Manager

Location: USA - NY - New York

Education Required: Refer to Position Description

Position Description:
Morgan Stanley & Co. LLC seeks International Tax Manager in New York, NY to under the direct supervision of a Senior Manager, who reports to a Vice President, function as an accountant/auditor, providing accounting support in the firm's annual tax compliance, quarterly tax provision, and international tax planning on restructuring foreign entities with regard to US and international corporate tax. Liaise with tax and business units controllers on items affecting the Firm's foreign tax credit analysis for Form 1118. Manage and consolidate Foreign Tax Credit (FTC) items into the executive summary template for Form 1118. Review the 901 tax credit of various jurisdictions for the FTC calculation prepared by subordinates. Engage in IRS IDR (Information Document Request) response regarding FTC related and non-UK European and Latin American entities. Assist with international tax compliance software testing and enhancements. Manage compliance related issues and tax planning analysis for Morgan Stanley's foreign subsidiaries and their hybrid subsidiaries in various European and Latin American jurisdictions. Prepare applicable US tax returns for Germany, Hong Kong, Mexico, Brazil, and Cayman Islands entities including Forms 5471, 8865, and 8858 using Tax Series (TTI) based on the local accounting and tax regulations. Review US tax returns for non-US entities including Forms 5471, 8865, and 8858 prepared by subordinates. Prepare quarterly analysis for the assigned entities for tax provision purposes to reflect current planning scenarios under consideration and capturing any significant U.S. tax accounting adjustments. Review analysis for quarterly effective tax rate determination and estimated tax payments prepared by subordinates. Prepare analysis for quarterly effective tax rate determination and estimated tax payments. Coordinate with the domestic compliance group with respect to any US inclusion items, such as subpart F, dividends and section 956 inclusions. Coordinate with members of the global tax group in projecting estimated tax liability of each legal entity and incorporate in tax planning analyses and effective tax rate calculations. Gather data for purposes of U.S. information reporting with regard to CFCs, CFPs and minority investments. Ensure that any tax law changes or structural changes are appropriately reported on the relevant US tax returns. Responsible for the Check-the-Box election of the foreign entities by preparing and filing the Form 8832 and SS-4, and maintaining the historical CTB entity list. Supervise Dual Consolidated Loss (DCL) analysis and monitor to minimize the certified DCL amount, and perform advisory role on the DCL and the triggering event for the tax planning. Research Internal Revenue Code (IRC) and Regulation to confirm and update tax return related analysis using various tax research tools including CCH and BNA. Utilize Excel modeling tools and Microsoft Office, and firms' financial database and firm's entity maintenance tool including Omega Suite and Tax Suite.

REQUIREMENTS

Master's degree in Business Administration, Economics, Finance, or related field or equivalent, and three (3) years of corporate accounting and international tax compliance experience on behalf of a global investment bank. Prior experience must include preparing various IRS forms including Forms 5471, 8858, and 8865 using Tax Series tax compliance tool; preparing Foreign Tax Credit for Form 1118; preparing 901 tax credits of various jurisdictions for FTC calculation; Check-the-Box election of the foreign entities by preparing and filing the Form 8832 and SS-4, and maintaining the historical CTB entity list; analyzing and monitoring Dual Consolidated Loss to minimize the certified DCL amount; applying local accounting and tax regulations of various foreign jurisdictions; researching Internal Revenue Code, Regulation, and Treaties for various jurisdictions using CCH and BNA research tools; and utilizing Excel modeling tool and Microsoft Office.

QUALIFIED APPLICANTS: Please apply through this website or e-mail your resume to efc115475@msresumes.com. NO CALLS. EOE

Skills Required:
Refer to Position Description

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