International Tax Accountant

This role will take the lead on technical tax issues related to the global firm's tax and filing obligations, primarily focused outside the US specifically in London and Asia. There will be involvement with all offices in the global footprint.  This role needs to liaise closely with the NY-based tax team who currently handle all US and foreign compliance tax matters and global partnership accounting. Can be based in NYC, CA, KS and/or the DC area.

• BEPS Pillar Two drafting and compliance

• Inter-firm invoicing to relieve cash trapped in foreign offices, interoffice balance review. 
• Taxing rights from certain countries and how that works if other jurisdictions claim taxing rights as well. 
• Permanent establishment, what it is, how it applies in various countries. 

• Partnership Accounting exp.
• Research treaty requirements and how they apply to a partnership with partners in multiple countries and how that may apply if we are working in a country that we do not have a permanent establishment. 
• Work with local offices with the preparation of tax workpapers and the cash to accrual analysis to determine exposure to foreign tax credit limitations at the individual level.  Will need to work heavily with the US team to understand Milbank’s unique entity and partner distribution structure. 
• Able to provide calculations of how foreign returns work from the cash to accrual conversion all the way through to the individual level so we can model that with the partnership accounts team to inform on how much and when to withhold branch taxes.
• Issuing inter-company invoices for re-charges and income recognition
• Liaising with the Firm’s NY tax team regarding global tax reporting & compliance predominantly for the partners located outside the US.
• Liaising with Firm’s NY tax team on US foreign tax credit reporting for US partners.
• Understanding the firm’s overall entity & tax structure and helping advise on efficient tax structuring.
• Maintaining non-US partners tax reserves for review by the US Tax Team.
• Developing global model(s) of partner income and distribution.
• Managing the relationships outside the US with the firm’s external professional advisers, lead tax partners in various offices and local tax authorities as needed.
• Proactively monitoring the potential consequences of changes in tax legislation and of the firm’s economics and advising the business on appropriate actions.
• Other ad hoc duties related to international taxation matters and partner remuneration and accounting such as but not limited to 

• VAT/GST and client-related withholding taxes
• Japanese QII
• Secondments
• Lateral partner recruitment
• Lawyer Relocations
• New office establishment

  Range: $150,000 to $200,000 (DOE)

• International law firm experience preferred open to candidates from the Big 4.
• Bachelor of Accounting required.
• Master of Taxation or Int. Tax or CPA preferred.
• ACA or ACCA qualified accountant or qualified by equivalent experience.
• Knowledge of US, UK and foreign tax required.
• Good experience with transfer pricing required.
• A good understanding of a multi-currency environment.
• An understanding of costs and balance sheet accounting.
• Demonstrated ability to think strategically and influence executive-level stakeholder decisions.
• An ability to present complex information in a clear and simple way.
• Able to work thoroughly with good attention to detail.
• Act with discretion and diplomacy with an appreciation for the confidential nature of the work.
• A good communicator.
• Able to prioritize and manage tasks in a high-pressure environment and meet strict deadlines.
• Flexible, team-player.