Montreal, Quebec, Canada
All Available Locations:
Montreal; Quebec City
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 Manager you will:
: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 ping), 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.
External Posting Qualifications 13;
:Completed undergraduate degree with outstanding academic credentials;
:A completed Masters degree in Taxation or CPA or LLB;
:Minimum 5 years of relevant work experience, preferably in a Big Four;
:References from former/current supervisors and/or clients;
:Superior verbal and written communication skills;
:Occasional Canadian travel required;
:Candidates must be able to enter the USA to work or attend tax technical courses.
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 differentiated talent experience that empowers our people withunlimited opportunities to do meaningful work and to grow, learn, and lead at every point in their career. Deloitte's newly designed offices offer unique workspaces that strengthen connections, inspire innovative ways of working, and provide the necessary tools to help you make an impact that matters. And with our global reach and network, you'll always be part of the Deloitte community.
"Once Deloitte, always Deloitte."
Lead yourself. Lead a team. Lead the firm. It's all possible at Deloitte.
Deloitte is one of Canada's leading professional services firms, providing audit, tax, consulting and financial advisory services across Canada.At Deloitte, we combine industry insight with a deep understanding of today's local and global busi