International Tax Specialist

U.S. International Tax Specialist – Legal Offshore Structuring & Global Tax Optimization

Location

Type

About the Role

U.S. International Tax Specialist

Key Responsibilities

• Advise on

  legal international tax minimization strategies

  for a U.S. person (citizen or green card holder).
• Design compliant international structures using

  foreign corporations, holding companies, trusts, or foundations

  .
• Implement strategies that mitigate exposure to

  GILTI, Subpart F, PFIC, and transition tax

  implications.
• Guide on

  territorial structuring

  , high-substance jurisdictions, and income deferral strategies.
• Set up

  offshore entities

  in tax-efficient jurisdictions (e.g., UAE, Singapore, BVI, Cook Islands, etc.) while ensuring IRS compliance.
• Oversee or assist in

  Form 5471, 8938, 8858, 926, and FBAR

  compliance.
• Coordinate with global legal and accounting professionals to implement structures.
• Monitor

  OECD BEPS initiatives

  , FATCA enforcement, and U.S. tax law changes to proactively adapt structures.
• Offer guidance on

  trust structuring, second citizenship, and offshore banking

  where applicable.

Ideal Candidate Profile

• 7+ years experience in

  U.S. international tax law, corporate structuring, or HNWI tax planning

• U.S. CPA, JD, or LLM in Taxation with demonstrated offshore experience
• Strong knowledge of

  GILTI, Subpart F, PFIC, CFC rules

  , and relevant

  IRC sections (Subchapter N & F)

• Experience working with

  high-net-worth U.S. persons or global entrepreneurs

• Capability to legally reduce

  effective tax rate

  while ensuring full compliance
• Familiarity with

  treaty arbitrage, hybrid entities, and holding structures

• Clear track record of

  setting up and maintaining offshore entities for U.S. clients

What You’ll Get

• Strategic influence on building a

  U.S.-compliant global tax structure

• Resources to implement structures, including legal/CPA support and entity registration
• Long-term engagement with growth-based compensation options
• Access to international operations and multi-jurisdictional opportunities