The International Tax Senior will report to the International Tax Manager in NOV’s Corporate Tax Department. This person will be expected to perform the following duties and responsibilities:
Prepare Form 1118, Foreign Tax Credit – Corporations, and supporting schedules and allocations. Perform/review associated calculations, including CFC stock basis, overall tax basis of assets, and interest expense apportionment. Evaluate stewardship and supportive cost allocations. Calculate/review sourcing of income for Form 1118 reporting.
Review of Forms 5471, 8865, 8858, and 1120-F and required disclosure statements. Prepare Forms 5471, 8865, 8858, and 1120-F for complex reporting structures and transactions, including foreign base company sales and services income calculations. Research and document return related tax issues as necessary.
Review of Forms W-8 (W-8BEN-E, W-8IMY, W-8ECI, etc.). Liaise with treasury and operations personnel regarding FATCA compliance. Research related issues as necessary.
Review of Forms 8802 and Forms 8821. Liaise with treasury and operations personnel regarding Residency Certifications. Research related issues as necessary.
Review financial statement information for the quarterly tax provision and prepare schedule of permanent differences related to foreign inclusions, including Section 78 gross-ups, Section 956 inclusions, Global Intangible Low-Taxed Income (GILTI) inclusions, and Subpart F inclusions, especially Foreign Base Company Income (FBCI) calculations. Analyze entity ledgers for Section 901 foreign tax credits and calculate overall foreign tax credit. Analyze dividends for proper reporting and inclusion in the quarterly tax provision.
Analyze foreign tax credit position, corporate tax strategy, and planning opportunities and provide tax advice to other organizational functions.
Prepare/review responses to Information Document Requests (IDRs) issued by the IRS exam team for tax years under audit, if applicable.
Assist with projects related to restructuring and acquisition implementation, including review and filing of Forms SS-4, Forms 8832, Forms 8023, Forms 8883, Forms 8594, FIRPTA filings, and other miscellaneous filings.
Assist in supervision of internal International Tax staff and third-party service provider loan staff, if applicable.
JOB REQUIREMENTS
Certified Public Accountant (CPA)
2-4 years work experience in International Tax; Big 4 experience preferred
Bachelor’s degree with emphasis in Accounting; Advanced degree in Accounting, Taxation, or Law preferred
Knowledge of CorpTax tax compliance software preferred