Sr Tax Attorney or CPA

GHSK is seeking a Senior Tax Attorney or CPA to lead technical review and legal advisory work for our international practice, focusing on cross-border issues for high-net-worth and ultra-high-net-worth individuals, families, and their entities. You will be the final reviewer on a substantial volume of complex foreign tax reporting. You will resolve complex domestic and international tax compliance issues, render legal opinions, research and advise regarding the International Revenue Code and international tax treaties, and represent clients in IRS controversy matters. This is substantially a senior review role; however, some limited preparation may be required for especially complicated returns. It reports directly to the Managing Partner, with significant client-facing responsibility and influence over how the practice runs.

Key Responsibilities

Technical Review and Oversight

• Serve as final reviewer on a high volume of U.S. tax returns for domestic and foreign filers (1040, 1040-NR, 1041, 1120, 1120-F, 1065, 709) and accompanying international informational returns (3520, 3520-A, 5471, 5472, 1116, 8621, 8938, 8865, 8858, and FinCEN 114 (FBAR), etc.).
• Perform and review PFIC analyses and Form 8621 filings, and advise clients accordingly.
• Review Form 5471 filings, including Subpart F, GILTI, and E&P determinations for clients' foreign holding companies and operating entities.
• Supervise the timely preparation and submission of Forms 3520/3520-A for foreign trusts, foreign gifts, and inheritances, including grantor and non-grantor trust analysis.
• Draft and defend treaty-based return positions, including residency tie-breaker analysis and Form 8833 disclosures.

Controversy and Remediation

• Represent clients before the IRS in examinations, audits, appeals, and penalty matters related to international reporting.
• Lead remediation of delinquent foreign filings, such as Voluntary Disclosures, Streamlined procedures, delinquent information return submissions. Assess penalty exposure and build reasonable-cause positions.

Leadership

• Mentor and train preparers and junior professionals, set review standards, and improve the quality and efficiency of the review process.
• Oversee technology used for tax preparation and research, evaluating and selecting the most appropriate software and related solutions for use by the team.
• Assigning work and overseeing submission process, especially at deadlines.

Qualifications

• For attorneys: JD required; LL.M. in Taxation strongly preferred. Active Bar admission in good standing in a U.S. jurisdiction; New York or Florida strongly preferred. For CPAs: Active CPA licensure required in Florida or New York.
• 12+ years of U.S. tax experience, with at least 7 years focused on international tax for HNW/UHNW clients at a law firm, accounting firm, or family office.
• Demonstrated experience as a reviewer of U.S tax returns for foreign filers at scale.
• Deep knowledge of PFIC, CFC, and foreign trust rules and U.S. income tax treaties.
• IRS controversy experience, including examinations, appeals, and penalty abatement.
• Strong command of U.S. federal income, estate, and gift tax law.
• Strong attention to detail.
• Strong preference for fluent speakers of Spanish and/or Portuguese.

What Success Looks Like

• High-volume review is accurate, defensible, and on schedule, including during peak season.
• Opinions and treaty positions hold up under IRS scrutiny.
• The tax preparation team gets measurably stronger under your supervision.

Skills and Attributes

• Exacting technical judgment and the confidence to own final sign-off.
• Polished, discreet client presence suited to UHNW families and their advisors.
• Able to explain complex positions in plain language.
• Thrives in a high-volume, deadline-driven environment without sacrificing accuracy.