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Recruiter
Attorney
Litigation - Whistleblower - CFTC
Tax
3-6 yrs required
Tax Attorney Senior Staff The candidate will represent the Corporation and assist the Tax Counsel and Senior Tax Counsel in the following areas: Perform general research of the Internal Revenue Code and other legal authorities, including applicable state law, to determine the tax consequences to LMC of various transactions. Prepare memoranda of law applying the research to specific fact situations and recommending appropriate responses that will minimize LMC's tax liabilities. Analyze and advise on income tax, payroll tax, withholding, deductibility and reporting aspects of employee fringe benefits, benefit plans, and executive compensation (including 162(m) (million-dollar cap), 280G (golden parachutes), 409A (nonqualified deferred compensation)). This does not include responsibility for ERISA or plan qualification issues, which are handled in the Law Department. Draft, review, and negotiate the tax provisions of agreements and other documents in corporate and partnership transactions (including M&A transactions) and financings, including interaction with LMC's outside counsel and counsel for the other parties to the transactions where appropriate. Prepare memoranda of law and audit responses to IRS and state audit issues to support the desired tax treatment of completed LMC transactions and tax return positions. Analyze new legislation, regulations, court decisions, and rulings for opportunities and impact on LMC and recommend appropriate responses that will minimize LMC's tax liabilities. Accurately summarize the tax consequences of completed transactions and instruct tax accounting personnel on the proper reporting of such transactions to taxing authorities.
Qualification and Experience
The candidate should have J.D. degree from accredited law school. Must be admitted to Bar in one state or DC. LL.M. in Tax a plus. Must have 3-6 years of tax legal experience, including major law firm training; 2-3 years with a corporate tax department a plus. Must have broad US transactional tax experience with good understanding of Subchapters C and K. Experience or some exposure to employee and executive compensation issues, including tax deductibility, withholding and reporting is needed. Must have strong tax research skills. Should have strong oral and written communications skills. Must have negotiation skills. Demonstrated ability to multi-task and handle multiple, sometimes conflicting priorities are needed.
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General Counsel Consulting is the leading in-house attorney search and placement firm in the United States dedicated exclusively to the placement of attorneys in corporations around the world. We represent Fortune 1000 and other corporations with their attorneys staffing needs, and we place attorneys in-house with corporations across the U.S. and around the world.