International Tax Adviser (USA)

Herbert Smith Freehills Kramer is a world-leading global law firm, where our ambition is to help you achieve your goals.

Exceptional client service and the pursuit of excellence are at our core. We invest in and care about our client relationships, which is why so many are longstanding. We enjoy breaking new ground, as we have for over 170 years.

As a fully integrated transatlantic and transpacific firm, we are where you need us to be. Our footprint is extensive and committed across the world’s largest markets, key financial centres and major growth hubs.

At our best tackling complexity and navigating change, we work alongside you on demanding litigation, exacting regulatory work and complex public and private market transactions. We are recognised as leading in these areas.

We are immersed in the sectors and challenges that impact you. We are recognised as standing apart in energy, infrastructure and resources. And we’re focused on areas of growth that affect every business across the world.

All of this is achieved by supporting the growth of our people, who help us deliver on our ambition – which is to help you achieve yours.

Herbert Smith Freehills Kramer: Your goals. Our ambition

The Opportunity

Key responsibilities

Preparation of information and schedules required to support non-US resident corporate, partnership and individual partner tax filings in the USA, including:

• Partner profit share ratios;

• Partner remuneration calculations;

• Ledger analysis of tax payments;

• Cash flow and tax distribution reconciliations;

• Other information, calculation or analysis as required.

Maintenance and reconciliation of tax records and ledgers, including but not limited to:

• Reconciliation of the USA federal and state income tax liabilities and payments;

• Assisting the Partner Finance team with the reconciliation of various balance sheet accounts for partners (worldwide tax payments including withholding tax and tax reserves);

• Assisting the Tax Processes & Controls team with regular reconciliation of partners' current and historic tax reserves, including the preparation of journals and data analysis.

Prepare, review and timely filing of all partner and partnership tax returns, K-1s, and other US tax computations and returns for non-US resident entities and partners.

• Ongoing oversight, monitoring and reconciliation of US tax reserves for non-US partners and non-US tax reserves for partners in the US, taking account of US profit fluctuations throughout the year.

• Analyse and calculate quarterly US tax prepayments due on behalf of non-US partners including assisting with the preparation of US state tax and PTET analysis.

• Overseeing the various administrative US tax processes, such as ITIN applications, information requests to partners, collating signatures for various IRS forms, etc.

• Coordinating the firm's tax compliance and preparation of information and schedules required to support the firm's global tax filings and partners' tax returns, including:

  • Working with other members of the International Tax team to maintain an accurate and up to date global partner population listing and profit allocation;

  • Preparation of DTR claims for UK resident partners in respect of tax liabilities in the US (and other jurisdictions as necessary);

  • Provision of other information as required by the UK tax team for preparation of the UK partnership and partner returns;

  • Provision of all necessary information, including responses received in respect of the Global Tax Compliance Questionnaire where applicable, in good time to local finance teams or tax return preparers in order to ensure all compliance deadlines are met;

  • Liaising with other law firms to ensure tax filings are coordinated for new and retiring partners;

  • Other information, calculation or analysis as required.

• Assisting with other tax responsibilities of the International Tax team, such as transfer pricing and withholding tax management.

• Payment of 3rd party tax adviser invoices and assisting with tracking spend against budget.

• Assisting the International Tax Manager, US and International Tax Manager and Head of International Tax on other tax projects that arise from time to time.

• Ensuring that any other tax compliance work required is produced to the highest of standards.

Key Performance Indicators

• Proactive, timely and clear communication of information to relevant stakeholders

• Proactive, timely and clear communication of information to relevant stakeholders

• Effective identification and management of compliance obligations and deadlines

• Maintenance of accurate and clear data and reconciliations

Qualifications, skills and experience

• Previous experience with managing US federal and state tax compliance obligations either for individuals and/or partnerships.

• We would expect the successful candidate to be part qualified (ACCA/CIMA/AAT/CTA/ATT/CPA) or with the desire to study, but will consider those with more or less experience, providing they meet the required competencies and can demonstrate successfully undertaking the above outlined responsibilities.

• Comprehension of basic accounting and journal entries.

• Professional partnership experience is desirable.

• Personal or corporate tax experience would be an advantage but is not essential.

• Advanced excel skills.

Competencies

• Personal Leadership

• Builds Authentic Relationships

• Collaborates with others

• Enhances the Client Experience

• Achieves Results

Team

Location

Contract type

Diversity & Inclusion

We are committed to attracting people from all backgrounds and creating a respectful and inclusive culture where everyone thrives. We see this as essential to our success, including our ability to innovate and achieve sustained high performance. This is a key part of our Values—Human, Bold, and Outstanding.