Fiscal Year

2023

Case Number

A-22125-50677

Case Status

Certified

Received Date

2022-06-21

Decision Date

2023-03-17

Refile

N

Original File Date

2023-01-01 07:59:28

Previous SWA Case Number State

Schedule A Sheepherder

N

Employer Name

Deloitte Tax LLP

Employer Name Slug

deloitte-tax-llp

Employer Address 1

1700 Market Street

Employer Address 2

Employer City

Philadelphia

Employer City Slug

philadelphia

Employer State

PENNSYLVANIA

Employer State Slug

pennsylvania

Employer Country

UNITED STATES OF AMERICA

Employer Postal Code

19103

Employer Phone

6179608170

Employer Number of Employees

7800

Employer Year Commenced Business

1989

NAICS Code

54121

FW Ownership Interest

N

Employer Contact Name

Marie Cumbest

Employer Contact Address 1

1700 Market Street

Employer Contact Address 2

Employer Contact City

Philadelphia

Employer Contact State/Province

PENNSYLVANIA

Employer Contact Country

UNITED STATES OF AMERICA

Employer Contact Postal Code

19103

Employer Contact Phone

6179608170

Employer Contact Email

permservices@deloitte.com

Agent Attorney Name

Sharon L Cook

Agent Attorney Firm Name

Seyfarth Shaw LLP

Agent Attorney Phone

(404) 885-6754

Agent Attorney Address 1

1075 Peachtree Street, N.E.

Agent Attorney Address 2

Suite 2500

Agent Attorney City

Atlanta

Agent Attorney State/Province

GEORGIA

Agent Attorney Country

UNITED STATES OF AMERICA

Agent Attorney Postal Code

30309

Agent Attorney Email

slcook@seyfarth.com

PW Track Number

P10021211492854

PW SOC Code

13-2011

PW SOC Title

Accountants and Auditors

PW Skill Level

Level IV

PW Wage

106371.00

PW Unit of Pay

Year

PW Wage Source

OES

PW Determination Date

2022-01-20

PW Expiration Date

2022-06-30

Wage Offer From

106371.00

Wage Offer To

123690.00

Average Salary

115030.50

Wage Unit of Pay

Year

Worksite Address 1

200 Berkeley Street

Worksite Address 2

Worksite City

Boston

Worksite City Slug

boston

Worksite State

MASSACHUSETTS

Worksite Postal Code

2116

Job Title

Tax Manager

Job Title Slug

tax-manager

Minimum Education

Master's

Major Field of Study

Finance

Required Training

N

Required Experience

N

Required Experience Months

Accept Alternative Field of Study

Y

Accept Alternative Major Field of Study

Accounting, Law, Business Administration, or related field

Accept Alternative Combination

Y

Accept Alternative Combination Education

Bachelor's

Accept Alternative Combination Education Years

5

Accept Foreign Education

Y

Accept Alternative Occupation

Y

Accept Alternative Occupation Months

36

Accept Alternative Job Title

performing project management and leading multifunctional teams

Job Opportunity Requirements Normal

N

Foreign Language Required

N

Specific Skills

Masters degree in Finance, Accounting, Law, Business Administration, or related field willing to accept foreign education equivalent plus three years of experience performing project management and leading multifunctional teams. In the alternative, the employer is willing to accept a bachelors degree and five years of experience as stated above. Experience must include two years of Reviewing and filing international tax compliance forms and informational returns, including Forms 1120F, 5471, 8865, 8858, 8621, 8990, and 8991 disclosures and statements; Reviewing calculations of Section 861 deductions, interest expense allocation, including 163j expense limitation, effectively connected income ECI, and branch profit tax BPT to estimate the U.S. income tax liability of foreign corporations; Reviewing proposed merger and acquisition documents and client data to analyze risks and opportunities on the tax implications of clients international operations, to develop optimal tax structures for corporate restructuring, corporate reorganization, mergers and acquisitions and IP migration strategy; Determining whether any of the foreign corporations held by private equity clients are Controlled Foreign Corporations CFCs by performing attribution calculation to determine ownership as well as calculating and reviewing Earnings and Profits and Tax Basis of CFCs and determining Subpart F, GILTI income and tax characterization of distribution made by CFCs; Reviewing passive foreign investment company PFIC analysis for private equity clients to determine whether any of the foreign investments could qualify as PFIC and subject to U.S. tax and prepare calculation to determine taxable income arising from such investments; Performing withholding analysis for Fixed, Determinable, Annual, Periodical FDAP Income of foreign corporations and partnerships; Reviewing international tax aspect of tax provisions, including Foreign Tax Credit, GILTI, BEAT, and FDII; Writing tax memoranda by utilizing CCH, BNA, Lexis Nexis and RIA Checkpoint to research various U.S. federal income tax issues and analyze tax rules and regulations of foreign jurisdictions; Providing international tax planning for outbound and inbound multinational companies to minimize global effective tax rate and satisfy business needs, including financing structuring, cash repatriation modeling, CFC planning, foreign exchange planning, and loss utilization modeling; and Leading the full lifecycle of client engagements, including managing resource requirement, project workflows, budgets, billing, and training, counseling, and mentoring junior team members.

Combination Occupation

N

Offered to Applicant Foreign Worker

Y

Foreign Worker Live on Premises

N

Foreign Worker Live in Domestic Service

N

Foreign Worker Live in Domestic Service Count

Professional Occupation

Y

Application for College/University Teacher

N

SWA Job Order Start Date

2022-02-14

SWA Job Order End Date

2022-03-21

Sunday Edition Newspaper

Y

First Newspaper Name

Boston Globe

First Advertisement Start Date

2022-02-27

Second Newspaper Ad Name

Boston Globe

Second Advertisement Type

Newspaper

Second Ad Start Date

2022-03-06

Employer Website From Date

2022-02-08

Employer Website To Date

2022-04-20

Professional Organization Ad From Date

2023-01-01 07:59:28

Professional Organization Advertisement To Date

2023-01-01 07:59:28

Job Search Website From Date

2022-02-28

Job Search Website To Date

2022-03-07

Employee Referral Program From Date

2022-02-08

Employee Referral Program To Date

2022-03-01

Local Ethnic Paper From Date

2023-01-01 07:59:28

Local Ethnic Paper To Date

2023-01-01 07:59:28

Radio/TV Ad From Date

2023-01-01 07:59:28

Radio/TV Ad To Date

2023-01-01 07:59:28

Employer Received Payment

N

Posted Notice at Worksite

Y

Layoff in Past Six Months

N

Country of Citizenship

CHINA

Foreign Worker Birth Country

CHINA

Class of Admission

H-1B

Foreign Worker Education

Master's

Foreign Worker Information: Major

ACCOUNTING

Foreign Worker Years of Education Completed

2018

Foreign Worker Institution of Education

UNIVERSITY OF NORTH CAROLINA AT CHAPEL HILL

Foreign Worker Education Institution Address 1

UNCCHAPEL HILL

Foreign Worker Education Institution Address 2

SUITE 3100, SASB NORTH, CB# 2100

Foreign Worker Education Institution City

CHAPEL HILL

Foreign Worker Education Institution State/Province

NC

Foreign Worker Education Institution Country

UNITED STATES OF AMERICA

Foreign Worker Education Institution Postal Code

27599

Foreign Worker Experience with Employer

N

Foreign Worker Employer Pays for Education

N

Foreign Worker Currently Employed

Y

Employer Completed Application

N

Preparer Name

Sharon L Cook

Preparer Title

Partner

Preparer Email

slcook@seyfarth.com

Employer Information Declaration Name

Marie Cumbest

Employer Information Declaration Title

Senior Manager