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Radio Show Host Talks His Way To A Win In Tax Court On Employment Status: Employee V. Independent Contractor

Radio Show Host Talks His Way To A Win In Tax Court On Employment Status

A radio show host demonstrated that he could talk as well in tax court as he could in front of a microphone. At issue was the question of whether or not a person can be an employee as well as an independent contractor simultaneously with the same employer.

During 2007, Juan A. Ramirez was employed by Univision as an on-air talent and program director for radio station KXTN in San Antonio, Texas. In addition, to hosting a five-hour, six days a week radio program, his contract also called for him to perform various other duties.

These duties included working as an announcer at the radio station, attending staff meetings, and promoting the station in general by making off air appearances. For those services, Mr. Ramirez received a base salary, bonuses and stock options in Univision, the parent company of KXTN. Ramirez’s employment agreement stated that his work was subject to the control of Univision and that he was to live up to Univision’s professional standards in all aspects.

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Director Transfer Pricing (San Diego, CA)

Transfer Pricing Director Job in San Diego, CA

Director, Transfer Pricing Job (Southern California)

High technology company locate in Southern California seeks Transfer Pricing Director to support the Global Head of Tax in developing and implementing operational and tax and transfer pricing strategies. This role supports the company’s operational model in a way that is consistent with legal and regulatory requirements around the world. A key objective of the Transfer Pricing Director is to understand the changing transfer pricing environment and manage transfer pricing risks globally. This includes managing questions raised by tax administrations, evaluating risks and opportunities, formulating and implementing transfer pricing policies around the world that meet the challenges of a highly complex and rapidly changing legal and regulatory environment.

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Director Transfer Pricing (San Diego, CA)

Director Transfer Pricing Job In San Diego, CA

Director, Transfer Pricing Job (Southern California)

High technology company locate in Southern California seeks Transfer Pricing Director to support the Global Head of Tax in developing and implementing operational and tax and transfer pricing strategies. This role supports the company’s operational model in a way that is consistent with legal and regulatory requirements around the world. A key objective of the Transfer Pricing Director is to understand the changing transfer pricing environment and manage transfer pricing risks globally. This includes managing questions raised by tax administrations, evaluating risks and opportunities, formulating and implementing transfer pricing policies around the world that meet the challenges of a highly complex and rapidly changing legal and regulatory environment.

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Director Transfer Pricing (San Diego, CA)

Director Transfer Pricing Job

Director, Transfer Pricing Job (Southern California)

High technology company locate in Southern California seeks Transfer Pricing Director to support the Global Head of Tax in developing and implementing operational and tax and transfer pricing strategies. This role supports the company’s operational model in a way that is consistent with legal and regulatory requirements around the world. A key objective of the Transfer Pricing Director is to understand the changing transfer pricing environment and manage transfer pricing risks globally. This includes managing questions raised by tax administrations, evaluating risks and opportunities, formulating and implementing transfer pricing policies around the world that meet the challenges of a highly complex and rapidly changing legal and regulatory environment.

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Senior Tax Manager- International (Sunnyvale, CA)

Senior Tax Manager - International

TaxConnections has been retained to conduct a search for a Senior Tax Manager – International for a global technology company headquartered in Silicon Valley, CA. .This position is responsible for providing international tax guidance for U.S. compliance and reporting; managing Americas region income tax compliance and related issues.

Responsibilities include:Review/provide technical guidance for international portion of company’s income tax return including Forms 8858, 5471, and 1118, GILTI, FDII, Subpart F and FTCs, as needed; Prepare/provide technical guidance for §861/other expense allocations for FDII benefit and foreign tax credits; Co-ordinate and manage review and approval of the international portion of Company’s U.S. tax return by external service providers, including technical analysis and discussion of issues raised; Research relevant international tax matters, new proposed and final regulations, tax law updates, and provide guidance for tax compliance and reporting; Prepare and manage U.S. tax return disclosures for international issues and transactions; Provide technical guidance to international compliance team for quarterly and year-end reporting.
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Senior Tax Manager- International (Sunnyvale, CA)

Senior Tax Manager- International (Sunnyvale, CA)

TaxConnections has been retained to conduct a search for a Senior Tax Manager – International for a global technology company headquartered in Silicon Valley, CA. .This position is responsible for providing international tax guidance for U.S. compliance and reporting; managing Americas region income tax compliance and related issues.

Responsibilities include:Review/provide technical guidance for international portion of company’s income tax return including Forms 8858, 5471, and 1118, GILTI, FDII, Subpart F and FTCs, as needed; Prepare/provide technical guidance for §861/other expense allocations for FDII benefit and foreign tax credits; Co-ordinate and manage review and approval of the international portion of Company’s U.S. tax return by external service providers, including technical analysis and discussion of issues raised; Research relevant international tax matters, new proposed and final regulations, tax law updates, and provide guidance for tax compliance and reporting; Prepare and manage U.S. tax return disclosures for international issues and transactions; Provide technical guidance to international compliance team for quarterly and year-end reporting.
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Senior Tax Manager – International (Silicon Valley, CA)

Senior Tax Manager - International (Silicon Valley, CA)

TaxConnections has been retained to conduct a search for a Senior Tax Manager – International for a global technology company headquartered in Silicon Valley, CA. This position is responsible for providing international tax guidance for U.S. compliance and reporting; managing Americas region income tax compliance and related issues.

Responsibilities include:Review/provide technical guidance for international portion of company’s income tax return including Forms 8858, 5471, and 1118, GILTI, FDII, Subpart F and FTCs, as needed; Prepare/provide technical guidance for §861/other expense allocations for FDII benefit and foreign tax credits; Co-ordinate and manage review and approval of the international portion of Company’s U.S. tax return by external service providers, including technical analysis and discussion of issues raised; Research relevant international tax matters, new proposed and final regulations, tax law updates, and provide guidance for tax compliance and reporting; Prepare and manage U.S. tax return disclosures for international issues and transactions; Provide technical guidance to international compliance team for quarterly and year-end reporting.
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Senior Tax Manager-International Compliance (Sunnyvale, CA)

Senior Tax Manager - International Compliance (Sunnyvale, CA)

TaxConnections has been retained to conduct a search for a Senior Tax Manager – International for a global technology company headquartered in Silicon Valley, CA. .This position is responsible for providing international tax guidance for U.S. compliance and reporting; managing Americas region income tax compliance and related issues.

Responsibilities include:Review/provide technical guidance for international portion of company’s income tax return including Forms 8858, 5471, and 1118, GILTI, FDII, Subpart F and FTCs, as needed; Prepare/provide technical guidance for §861/other expense allocations for FDII benefit and foreign tax credits; Co-ordinate and manage review and approval of the international portion of Company’s U.S. tax return by external service providers, including technical analysis and discussion of issues raised; Research relevant international tax matters, new proposed and final regulations, tax law updates, and provide guidance for tax compliance and reporting; Prepare and manage U.S. tax return disclosures for international issues and transactions; Provide technical guidance to international compliance team for quarterly and year-end reporting.
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Senior Tax Manager – International (Sunnyvale, CA)

Senior Tax Manager - International (Sunnyvale, CA)

TaxConnections has been retained to conduct a search for a Senior Tax Manager – International for a global technology company headquartered in Silicon Valley, CA. .This position is responsible for providing international tax guidance for U.S. compliance and reporting; managing Americas region income tax compliance and related issues. The ideal individual will also be highly versed in US/Canadian and US/Mexican operations although our client is in more than 100 countries worldwide.

Responsibilities include:Review/provide technical guidance for international portion of company’s income tax return including Forms 8858, 5471, and 1118, GILTI, FDII, Subpart F and FTCs, as needed; Prepare/provide technical guidance for §861/other expense allocations for FDII benefit and foreign tax credits; Co-ordinate and manage review and approval of the international portion of Company’s U.S. tax return by external service providers, including technical analysis and discussion of issues raised; Research relevant international tax matters, new proposed and final regulations, tax law updates, and provide guidance for tax compliance and reporting; Prepare and manage U.S. tax return disclosures for international issues and transactions; Provide technical guidance to international compliance team for quarterly and year-end reporting. Review calculations for technical accuracy; Manage, supervise and train team member supporting international provision in direct tax hub offshore; Coordinate with Finance shared services centers, GL accounting, revenue and other teams on various international tax issues and more.

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Tax Manager – Investment Management (San Francisco, CA)

Tax Manager - Investment Management (San Francisco, CA)

TaxConnections is conducting a search for an investment management group to fill a Tax Manager role located in San Francisco, CA. We would genuinely appreciate your review of this opportunity and kindly refer this to anyone you believe who may appreciate learning more.

The Tax Manager will be responsible for assisting senior tax management with tax research and planning and all aspects of the tax compliance and forecasting for a very significant investment partnership and the related investment management entity. Individual must have a solid understanding of current tax laws including knowledge of investment partnership structures.

Researching and communicating the tax consequences of current and proposed investments will be a part of the responsibilities of the successful candidate. In addition, the position will require both the preparation and review of highly detailed complex Federal, California and multi-state income tax returns, foreign investment reporting implications, preparation of tax forecasts and researching complex tax issues.  The Tax Manager must be able to perform multiple tasks, have proven project management skills and produce high quality, accurate and detailed work on a timely basis. Also, must be able to timely identify and communicate issues, positions, and opportunities both orally and in writing to management.

Responsibilities include the following:
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Tax Manager – Research And Planning (San Francisco, CA)

TaxConnections is conducting a search for an investment firm to fill a Tax Manager role located in San Francisco, CA. We would genuinely appreciate your review of this opportunity and kindly refer this to anyone who may appreciate learning more.

The Tax Manager will be responsible for assisting senior tax management with tax research and planning and all aspects of the tax compliance and forecasting for a very significant investment partnership and the related investment management entity. Individual must have a solid understanding of current tax laws including knowledge of investment partnership structures.

Researching and communicating the tax consequences of current and proposed investments will be a part of the responsibilities of the successful candidate. In addition, the position will require both the preparation and review of highly detailed complex Federal, California and multi-state income tax returns, foreign investment reporting implications, preparation of tax forecasts and researching complex tax issues.  The Tax Manager must be able to perform multiple tasks, have proven project management skills and produce high quality, accurate and detailed work on a timely basis. Also, must be able to timely identify and communicate issues, positions, and opportunities both orally and in writing to management.

Responsibilities include the following:
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Senior Tax Specialist – San Francisco, CA

Senior Tax Accountant Tax Job,, San Francisco, CA

TaxConnections is conducting a search for a Senior Tax Specialist for an investment group in San Francisco,CA. If you know of anyone interested in learning more about this exciting opportunity, please forward refer and forward this on to them today.

The Senior Tax Specialist is responsible for performing tax compliance and planning functions as well as providing tax support for various entities, which may include Partnerships, Limited Liability Companies and Corporate entities.  Significant emphasis will be on tax work related to Partnerships and Limited Liability Companies. Prepare federal and state income tax returns and forecasts and perform various tax planning and research projects that involve a high degree of complexity.  Respond to audits by and information requests from various government authorities. Responsibilities include the following:
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