Activate Talent

45416593928 - International Tax Lawyer

Activate Talent  •  Federative Republic of Brazil (Remote)  •  2 months ago
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Job Description

International Tax Lawyer

Remote – London Time Zone Shifted Support
Full Time | Independent Contractor

About the Company

We help high-net-worth individuals, families, and businesses reduce tax exposure, navigate complex cross-border regulations, and optimize their global asset structures. Our boutique advisory firm combines deep legal expertise with strategic foresight, providing solutions that transcend national borders — a true embodiment of our company's ethos

We believe in proactive planning, tailored structures, and exceptional service, enabling our clients to thrive in an increasingly complex global environment.

We are seeking a seasoned International Tax Lawyer to advise on high-level, cross-border tax planning, structuring, compliance, and controversy matters. You will work with a multidisciplinary team of investment, legal, and operational experts to deliver sophisticated tax strategies for global clients — including families, entrepreneurs, and businesses — with assets and activities across multiple jurisdictions.

This is a remote role with London time zone shifted support to ensure optimal collaboration with clients and colleagues across Europe, the Americas, and beyond.

Key Responsibilities

Advisory & Structuring

  • Advise on international tax matters related to:
    • Cross-border entity structuring (e.g., holding companies, trusts, foundations)
    • Withholding tax, transfer pricing, and treaty application
    • Tax-efficient repatriation strategies: dividends, royalties, interest, capital gains
    • Tax residency, citizenship planning, and exit taxation
  • Design and implement compliant, tax-efficient structures for global clients

Compliance & Risk Management

  • Oversee global tax compliance across jurisdictions:
    • FBAR, FATCA, CRS, Form 5471/8865, CbC reporting, etc.
  • Coordinate cross-border filings and ensure timely compliance
  • Monitor and advise on changes in international tax laws and regulatory frameworks

Tax Controversy & Defense

  • Represent clients in cross-border tax disputes, audits, and assessments
  • Liaise with tax authorities and local counsel to manage tax controversies
  • Negotiate favorable outcomes and mitigate penalties

Legal Advisory & Drafting

  • Conduct legal due diligence for international transactions (M&A, capital movements, IP, financing)
  • Draft and review intercompany agreements, royalty/service contracts, loan agreements, etc.
  • Advise on international estate, gift, and wealth transfer planning

Team & Network Development

  • Mentor junior lawyers and associates
  • Build and maintain a global network of trusted legal and tax advisors
  • Collaborate with internal teams to align tax strategy with investment and estate planning

Requirements

  • JD / LLM in Tax or equivalent legal qualification
  • Admitted to practice in at least one major jurisdiction (e.g., U.S., UK, or EU member state)
  • 5–8+ years’ experience in international tax law (law firm, Big Four, or boutique advisory)
  • Expertise in:
    • U.S. international tax (Subpart F, GILTI, PFICs, IRC §§ 385/367/956)
    • OECD BEPS framework and EU Anti-Tax Avoidance Directives
    • Treaty interpretation and CFC regimes
  • Track record in:
    • Cross-border structuring and M&A
    • Tax controversy and defense
    • Intercompany pricing and contracts
  • Strong drafting and client communication skills
  • Fluent in English (required); Spanish, Portuguese, Mandarin, or French strongly preferred
  • Willingness to travel internationally as needed

Key Competencies & Attributes

  • Strategic Sees tax in the context of broader legal, financial, and business goals
  • Proactive Stays ahead of regulatory changes and client needs
  • Client-Focused Prioritizes bespoke, high-impact solutions
  • Collaborative Works well across cultures and disciplines
  • Ethical & Compliance-Oriented Balances innovation with risk management
  • Analytical & Creative Brings a problem-solving mindset to complex tax issues

Reporting & Team Structure

  • Reports to: Head of Legal / Chief Legal Officer
  • Collaborates with: Strategy, Investment, Private Client, and Operations teams
  • Potential to lead a small team of associates or specialists as the firm grows

Performance Metrics

  • Successful implementation of tax-optimized, compliant structures
  • High client satisfaction, retention, and referrals
  • Minimization of audit risks and favorable controversy outcomes
  • Expansion of the global legal/tax advisor network
  • Contributions to thought leadership and global brand visibility

Benefits

Why Join the Company?

  • Work with sophisticated global clients on high-impact, cross-border issues
  • Collaborate with a world-class, entrepreneurial team
  • Fully remote with international exposure
  • Opportunity to grow into a leadership role
  • Shape the future of global tax planning from anywhere

Apply today to help sophisticated clients go further — without borders.

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About Activate Talent

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Industry
HR & Recruiting
Company Size
51-200 employees
Headquarters
Los Angeles, CA
Year Founded
Unknown
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