Managing Director(s) (San Francisco, CA)

Responsibilities: Advise multinational enterprises on the application of U.S. Internal Revenue Code and Treasury regulations relating to the taxation of domestic partnerships and corporations. Review legal structures and provide advice on U.S. tax implications of potential alternative structures and restructurings, including character, timing and source of gains. Provide tax guidance related to share and asset sale agreements, financing documents, partnership agreements, joint venture agreements, and merger and demerger agreements.

Analyze the tax implications of U.S. tax elections and the resulting impact on deemed distributions and contributions. Prepare memoranda regarding cross-border transactions, key assumptions, tax issues, and conclusions.

WORK SCHEDULE: 40 hours per week, M-F (9:00am – 5:00pm)

JOB REQUIREMENTS:Bachelor’s degree in Finance, Taxation or a related field plus ten (10) years of experience in the offered position or a related occupation. Alternatively, employer will accept a master’s degree plus seven (7) years of experience. Three (3) years of experience must include: Structuring the tax aspects of multinational Private Equity and strategic mergers, acquisitions, joint ventures, dispositions, and IPOs; advising on U.S. and non-U.S.

REIT structures, partnerships, and Asset Management structures; advising on the application of tax treaty provisions and limitation of benefits provisions; preparing partnership tax returns, partnership allocations, carried interest waterfall calculations, and withholding tax calculations; and Controlled Foreign Corporation Participation Exemption rules. Telecommuting may be permitted within commutable distance from the office location depending on business need.

TRAVEL REQUIREMENT: Up to 20% travel to various domestic locations per business need.

QUALIFIED APPLICANTS: Apply online at https://www.kpmguscareers.com/job-search and type requisition number 139718 in the keyword search box for Experienced Professionals. Should you have any difficulty in applying for this position through our website, please contact: [email protected] for assistance in the application process.

Must have legal right to work in U.S. if offered employment. Comprehensive compensation & benefits offered. KPMG is an EOE/disability/veteran and maintains a drug-free workplace. No phone calls or agencies.

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