Tax Senior Manager [Inpatriate/Expatriate]

Opportunity ID

10093

Department

Tax

Location(s)

Boca Raton, Jupiter, Miami, Sunrise

State

Florida

Function

National Tax

Job Description

As CohnReznick grows, so do our career opportunities. As one of the nation's top professional services firms, CohnReznick creates rewarding careers in advisory, assurance, and tax with team members who value innovation and collaboration in everything they do!

CohnReznick helps organizations optimize performance, manage risk, and maximize value through CohnReznick LLP (assurance services) and CohnReznick Advisory LLC (advisory and tax services). Together, the firm provides leaders with deep industry knowledge and relationships, solutions to address clients' unique business goals and risks, and insight on how emerging market forces can drive opportunity. With offices nationwide, the firm serves organizations around the world as an independent member of Nexia.

We currently have an exciting career opportunity for a Tax Senior Manager to join the International Tax team in our National Tax practice.

CohnReznick is a hybrid firm and most of our professionals are located within a commutable distance to one of our offices. This position is considered hybrid which means team members are expected to be thoughtful and intentional in how they create opportunities for in-person collaboration. While the cadence of in-office presence is determined at the team level, our professionals are encouraged to be in the office/together in person on average 3 days a week.

YOUR TEAM.

This position will support our National International Tax Services practice, with a particular focus on entrepreneurial and high-net-worth individuals whose personal, business, investment and family interests cross international borders.

Our clients include U.S. citizens and residents living or investing abroad, foreign individuals moving to or investing in the United States, entrepreneurs and business owners with interests in foreign corporations and partnerships, international executives, globally mobile families, investors in foreign funds, and individuals considering immigration, residency or expatriation decisions.

The Senior Manager will lead technically complex U.S. individual income tax engagements that frequently combine international tax compliance and consulting, private-client planning, closely held business interests, foreign investments, trusts and estates, multistate considerations and cross-border transactions.

This is a highly visible role requiring strong technical judgment, client leadership, team development and proven business development capabilities. The Senior Manager will work closely with Partners while independently managing sophisticated client relationships and helping expand the National International Tax Services practice.

WHY COHNREZNICK?

At CohnReznick, we're united by a common mission to create opportunity, value, and trust for our clients, our people, and our communities. Whether it's working alongside your peers to solve a client challenge, or volunteering together at the local food bank, there are so many ways to find your "why" at the firm.

We believe it's important to balance work with everyday life - and make time for enjoyment and fun. We invest in a robust Total Rewards package that includes everything from generous PTO, a flexible work environment, expanded parental leave, extensive learning & development, and even paid time off for employees to volunteer.

YOUR ROLE.

As a Tax Senior Manager, you will lead complex U.S. tax compliance and consulting engagements for entrepreneurial and high-net-worth individuals with international business, investment and family interests.

Responsibilities include but not limited to:

• Lead and review complex Forms 1040 and 1040-NR for U.S. citizens, resident aliens, nonresident aliens, dual-status taxpayers and internationally mobile individuals.
• Serve as a trusted tax advisor to entrepreneurs, high-net-worth individuals, business owners, executives and globally mobile families on complex U.S. and international individual tax matters.
• Advise on U.S. tax residency, including the green card and substantial presence tests, closer-connection positions, treaty tie-breaker positions, dual-status taxation and residency-starting and termination dates.
• Lead complex foreign tax credit analyses involving Forms 1116, income sourcing, treaty resourcing, foreign tax redeterminations, credit carryovers and expense allocation and apportionment.
• Review and advise on international reporting requirements involving Forms 5471, 8865, 8858, 8621, 926, 3520/3520-A, 8938, 8833, 8854, FinCEN Form 114 and related filings.
• Advise individual taxpayers on foreign corporation matters, including CFC status, constructive ownership, Subpart F, GILTI, Section 962 elections, previously taxed earnings and profits, distributions and other shareholder-level consequences.
• Lead the analysis of foreign investment portfolios and PFIC reporting, including QEF elections, mark-to-market elections, Section 1291 calculations, annual inclusions, distributions and dispositions.
• Review foreign partnership and private-investment-fund reporting, including entity classification, Forms K-1 and K-3, underlying PFIC investments, foreign-source income and partner-level international reporting obligations.
• Advise entrepreneurial clients on the interaction between the individual income tax return and interests in U.S. and foreign partnerships, S corporations, C corporations, foreign corporations, trusts and disregarded entities.
• Understand and identify the application of basis, at-risk, passive activity, NIIT, excess business loss, Section 163(j) and related limitations within complex individual tax engagements.
• Lead tax matters involving foreign trusts and estates and internationally connected grantors and beneficiaries, including the interaction between individual income taxation and international information reporting.
• Advise on foreign pension, retirement and deferred-compensation arrangements and their interaction with U.S. income taxation, treaty provisions and information reporting.
• Advise clients regarding pre-immigration and expatriation planning, including long-term residency, Form 8854, Section 877A and related pre- and post-expatriation considerations.
• Review foreign financial statements, tax returns, brokerage statements, investment-fund reporting and other foreign-source documentation and determine appropriate treatment for U.S. tax purposes.
• Provide technical oversight of amended returns, delinquent international filings, IRS Streamlined Filing Compliance Procedures and other international compliance remediation matters.
• Lead tax projections, estimated-tax calculations, extensions and cash-tax planning for clients with significant income and investments across multiple entities and jurisdictions.
• Coordinate with attorneys, investment advisers, family offices, foreign tax advisers and other professionals to deliver integrated solutions to sophisticated private clients.
• Manage multiple complex engagements under compressed deadlines while maintaining technical accuracy, client responsiveness and appropriate review standards.
• Demonstrate the ability to lead effectively under significant time pressure, prioritize competing client demands and make sound professional judgments during peak filing periods.
• Manage engagement economics, including scoping, budgeting, staffing, realization, billing and collections.
• Direct and review the work of Senior Associates, Associates and offshore professionals and provide clear, technically substantive and actionable review comments.
• Develop junior professionals through coaching, technical training, delegation and Career Advisor responsibilities.
• Demonstrate a proven track record of business development, including generating new client opportunities and expanding relationships with existing clients.
• Identify additional international tax, private-client and related advisory opportunities arising from client business, investment and family activities.
• Participate actively in prospect meetings, proposal development, pricing discussions, engagement scoping and new-client onboarding.
• Build and maintain relationships with external referral sources, including attorneys, wealth managers, family offices, financial advisers, foreign accounting firms and other professional-service providers.
• Work with Partners to develop and execute market strategies targeting entrepreneurial and high-net-worth international individuals.
• Represent the firm through conferences, professional organizations, client events, webinars, presentations, articles and other thought-leadership activities.
• Develop a personal professional network and market presence that contributes to the continued growth of the National International Tax Services practice.
• Demonstrate the ability to convert technical expertise and strong client service into expanded engagements, referrals and new client relationships.

YOUR EXPERIENCE.

The successful candidate will have:

• Bachelor's degree in Accounting required.
• Active CPA license required.
• Significant progressive tax experience with substantial involvement in complex individual and international individual taxation.
• Significant experience reviewing and taking ownership of complex Forms 1040 and 1040-NR, including responsibility for tax positions and related international reporting.
• Experience serving entrepreneurial and high-net-worth individuals, business owners, executives, internationally mobile families and closely held businesses with foreign investments or transactions.
• Strong technical knowledge of U.S. residency, income sourcing, foreign tax credits and U.S. income-tax treaties.
• Strong working knowledge of international individual tax provisions, including PFIC, CFC, Subpart F, GILTI, Section 962, FIRPTA, FDAP and Section 877A expatriation taxation.
• Experience reviewing international information reporting such as Forms 5471, 8865, 8858, 8621, 926, 3520/3520-A, 8938, 8833 and 8854 and FBARs.
• Proven experience identifying and addressing the individual income tax consequences of closely held S corporations, partnerships and other business interests.
• Experience with cross-border trusts and the tax and reporting consequences affecting U.S. and non-U.S. grantors and beneficiaries.
• Experience with IRS Streamlined Filing Compliance Procedures and other international tax-compliance remediation matters.
• Ability to analyze sophisticated Forms K-1 and K-3, foreign financial statements and tax returns, brokerage statements, investment-fund reporting and other complex financial information.
• Strong tax research and technical-writing skills and the ability to develop and defend technically supportable positions.
• Demonstrated ability to independently resolve complex, fact-intensive tax issues and recognize matters requiring Partner or specialist involvement.
• Demonstrated ability to perform effectively under tight deadlines and significant pressure while maintaining technical accuracy, sound judgment and high client-service standards.
• Proven ability to simultaneously lead multiple complex client engagements and effectively prioritize rapidly changing deadlines and client demands.
• Proven experience managing engagement economics, including budgets, staffing, billing and collections.
• Proven business development experience, including originating opportunities, expanding existing client relationships, participating in proposals and prospect meetings, and developing professional referral relationships.
• Demonstrated ability to develop and maintain trusted relationships with sophisticated clients and their attorneys, investment advisers, family offices, wealth managers and foreign tax advisers.
• Proven ability to lead, mentor and develop tax professionals at multiple levels.
• Strong written and verbal communication skills, including the ability to explain highly technical international tax issues clearly to clients and other advisers.

In addition, please take a moment to review our Universal Job Standards.

Studies have shown that we are less likely to apply to jobs unless we meet every single qualification. At CohnReznick, we are dedicated to building a diverse, equitable, and inclusive workplace, so if you're excited about this role but your experience doesn't align perfectly with every qualification in the job description, we still encourage you to apply. You may be just the right candidate for this or one of our other roles.

"CohnReznick" is the brand name under which CohnReznick LLP and CohnReznick Advisory LLC and their respective subsidiaries provide professional services. CohnReznick LLP and CohnReznick Advisory LLC (and their respective subsidiaries) practice in an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations, and professional standards. CohnReznick LLP is a licensed CPA firm that provides attest services to its clients. CohnReznick Advisory LLC provides tax and business consulting services to its clients. CohnReznick Advisory LLC and its subsidiaries are not licensed CPA firms.

CohnReznick is an equal opportunity employer, committed to a diverse and inclusive team to drive business results and create a better future every day for our team members, clients, partners, and communities. We believe a diverse workforce allows us to match our growth ambitions and drive inclusion across the business. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, age, national origin, or protected veteran status and will not be discriminated against on the basis of disability. For more information, please see Equal Employment Opportunity Posters.

If you are an individual with a disability in need of assistance at any time during our recruitment process, please contact us at CRaccommodation@CohnReznick.com Please note: This email address is reserved for individuals with disabilities in need of assistance and are not a means of inquiry about positions or application statuses.

CohnReznick does not accept unsolicited resumes from third-party recruiters unless such recruiters are currently engaged by CohnReznick Talent Acquisition Team by way of a written agreement to provide candidates for a specified opening. Any employment agency, person or entity that submits an unsolicited resume does so with the understanding that CohnReznick will have the right to hire that applicant at its discretion without any fee owed to the submitting employment agency, person or entity.

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