This article is the second in a series that will focus on tax specialties that are in demand today. Some are often overlooked or misunderstood by tax professionals who are looking to find their niche in the tax profession. One such hot specialty today is International Tax. Many have read the recent accounts of large corporations facing enormous tax assessments around the globe. International taxation is certainly a hot field and will definitely intensify going forward. Corporations, public accounting firms, and law firms are in great need of international tax specialists.
For our purposes, international tax is defined as the U.S. taxation of international or cross-border transactions. A U.S. tax professional generally is not permitted by law or its professional liability insurance to provide advice on foreign tax law. Local tax specialists are ordinarily consulted with respect to taxation in the non-U.S. country.
Although international tax is viewed as a specialty, it is a very broad area that has spawned its own sub-specialties. International transactions can be separated into outbound and inbound. Outbound transactions involve U.S. taxpayer engaging in foreign transactions. Inbound transactions involve foreign taxpayers engaging in U.S. transactions. Many of the larger firms have created sub-specialties where international tax professionals specialize in either outbound or inbound transactions. Other hot sub-specialties include transfer pricing (which has its own sub-specialties), FIRPTA (inbound real estate taxation), foreign currency exchange, cross-border acquisitions and reorganizations, cross-border financial product taxation, as well as tax compliance and tax planning.
Transfer pricing is extremely hot today and professionals are in great demand. In general, transfer pricing is the determination of the appropriate price to be charged for goods, services, or intellectual property rights among related entities. Many of the large tax audit deficiencies involve transfer pricing. Accountants or lawyers that have a degree or background in economics are excellent candidates for transfer pricing positions in corporate, public accounting and law firms. There are also boutique firms that specialize in transfer pricing. As mentioned above, transfer pricing has a few of its own sub-specialties, such as Transfer Pricing Tax Controversy (handling IRS audits and appeals) and Transfer Pricing Tax Litigation.
Breaking into an international tax group within a firm can be competitive. Typically, the larger firms chose new entrants into this field that are high performers or have some prior background in international tax. International tax is some of the most complex tax law in the Internal Revenue Code. I find international tax compliance, tax research, and tax planning very challenging, but very gratifying in terms of solving difficult problems and issues, and helping clients. If international tax interests you, make it known to your firm early in your career that international tax is part of your career goals. Strive to attend introductory seminars and webinars – there are many very good “boot camps.” If you are enrolled in a Master's of Tax program (either the MST or the LLM), take any and all of the international tax courses offered.
By: Paul N. Iannone, JD, CPA, MST
Founder of Tax Career Advisor, LLC and Author of “Extraordinary Tax Career”
Tax Career Advisor, LLC provides customized career coaching for tax and accounting professionals and consulting to C.P.A. firms and corporations.
