International Tax Consultant

2 weeks ago

Mumbai, Maharashtra, India Arcot Group Full time

Job Title: International Tax Consultant (U.S./India/UAE)

Location: Mumbai

About Us

We are a cross-border business operation with entities in the United States (Delaware/New Jersey), India, and the UAE. We have a complex structure involving single-member LLCs, foreign corporations (potentially classified as CFCs), and multi-country service contracts. We are looking for an experienced International Tax Consultant who can guide us through U.S. and international tax planning, compliance, and optimization—especially around GILTI, Subpart F, Section 962, transfer pricing, and foreign tax credits.

Key Responsibilities
  1. Tax Planning & Compliance
  • Develop and implement tax strategies to minimize global tax exposure, leveraging U.S. international tax laws, India-specific regulations, and UAE requirements.
  • Ensure timely and accurate federal (IRS) and state (e.g., New Jersey) tax filings, including international information returns (Forms 5471, 8992, FBAR, 8938, etc.).
Global Structuring & Advisory
  • Advise on business structuring for multi-entity operations across the U.S., India, and UAE, with attention to Subpart F and GILTI rules for Controlled Foreign Corporations (CFCs).
  • Analyze and recommend Section 962 elections and handle corresponding calculations and documentation.
Transfer Pricing
  • Review and establish arm's-length pricing for cross-border transactions between UAE and India entities, and the U.S. entity.
  • Document intercompany agreements and support transfer pricing analyses to satisfy both U.S. and foreign tax authorities.
Resident & Non-Resident Tax Issues
  • Provide guidance on domicile/residency questions (e.g., New Jersey vs. non-residency) and related state-level tax implications.
  • Assist with personal tax planning for a U.S. citizen living abroad (India/UAE), ensuring compliance with FBAR, foreign tax credits, and relevant exclusions/deductions.
Cross-Border Income & Credit Optimization
  • Compute and optimize usage of foreign tax credits, plan for double taxation relief, and leverage tax treaties (where applicable).
  • Model different scenarios for distribution vs. retention of foreign profits, including implications of second-layer dividend taxation under Section 962.
Ongoing Advisory & Best Practices
  • Keep abreast of changes in U.S. tax law (TCJA updates, new regulations) and foreign tax regimes (India's corporate tax, UAE's new 9% tax regime).
  • Serve as a trusted advisor for all matters related to international expansion, invoicing structures, and compliance.
Qualifications
  • Education & Certification:
    • CPA or EA strongly preferred; LLM in Taxation or JD with specialization in international tax a plus.
    • Demonstrable expertise in U.S. international taxation (GILTI, Subpart F, PFIC, Section 962).
  • Technical Expertise:
    • Hands-on experience preparing or reviewing Forms 5471, 8992, 8993, 8865, FBAR (FinCEN 114), and Form 8938.
    • In-depth knowledge of transfer pricing regulations and documentation requirements.
    • Familiarity with India corporate taxation (TDS, withholding rules, corporate tax rates) and UAE tax updates (particularly the 9% corporate tax regime).
  • Professional Experience:
    • 5+ years of relevant cross-border tax experience (public accounting or specialized boutique firm).
    • Proven track record advising U.S. citizens living abroad on complex multi-entity structures and personal tax liabilities.
    • Experience navigating state residency and domicile issues, especially in New Jersey.
  • Soft Skills:
    • Excellent analytical and problem-solving abilities with attention to detail.
    • Strong communication skills; able to convey complex tax strategies to both financial and non-financial stakeholders.
    • Proactive, solution-oriented approach; comfortable handling evolving international regulations.
Preferred Attributes
  • Familiarity with small and mid-sized cross-border businesses, including tech/AI/software services.
  • Knowledge of India–U.S. and UAE–U.S. tax treaty considerations (where applicable).
  • Experience implementing Section 962 strategies and modeling second-layer tax scenarios.
  • Competence with international tax software and workflow tools (e.g., GoSystem, OneSource, CCH Axcess).
Why Join Us
  • High-impact role: You'll shape our global tax strategy and ensure compliance for a fast-growing, multi-entity structure.
  • Dynamic environment: Work directly with the founder/CEO and key stakeholders across the U.S., India, and UAE.
  • Competitive compensation: We value expertise and offer remuneration commensurate with experience and results.

How to Apply
Please send your resume, a brief cover letter, and examples of relevant international tax projects (or client references) to [Your Email or Online Form Link]. Include "International Tax Consultant Application" in the subject line.

We are an Equal Opportunity Employer and encourage applications from all qualified professionals who meet the criteria. We look forward to exploring how your expertise can help us optimize our global tax structure and ensure ongoing compliance

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