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Tax Attorney in San Jose, CA

PricewaterhouseCoopers LLP. Nov 17,2016 Aug 10,2016 Location San Jose CA
This job is expired...

In-House

Attorney

Litigation - Whistleblower - CFTC

Tax

Min 3 yrs required

Profile

Tax Manager - Mergers and Acquisition Duties: Advises private equity, multinational corporations, privately held companies, and partnerships on the tax aspects of due diligence, planning, structuring, and executing transactions of all sizes. The group assists its clients in all facets of M&A tax, including the following: buy side and vendor tax due diligence; proposed restructuring and acquisition transactions; proposed corporate carve-outs and other disposition transactions; IPO planning; interpretation of complex statutory and regulatory actions relating to corporate and partnership transactions; quantitative analysis to assess the tax consequences of specific transactions; regulatory and legislative initiatives; troubled company restructuring and bankruptcy procedures; and preparation for client review submission requests for private letter rulings and technical advice from the IRS. Will work with C-Suite executives and senior tax professionals and will analyze proposed transactions for unusual tax risks or undetermined tax benefits, advise clients on tax-efficient restructurings, interpret complex legislative and regulatory actions relating to corporate and partnership transactions, perform financial analysis to assess the tax consequences of specific transactions, assist clients with regulatory and legislative initiatives, and prepare for client review submission requests for private letter rulings and technical advice from the IRS.

Qualification and Experience

Requirements: Bachelor's degree in Accounting. CPA, Enrolled Agent or Member of the Bar. JD Degree or Master's degree with Accounting or Tax, or in Taxation preferred. 3+ years' experience. Knowledge of, and/or success in roles managing, the performance of financial analyses to assess key aspects of M&A practices--including corporate M&A, private equity, post-deal integration, bankruptcy and corporate insolvency--as it relates to a global network of professional services consulting firms, including the following areas: Tax consulting and planning--e.g. analyzing proposed transactions for unusual tax risks for undetermined tax benefits; Transaction structuring for tax issues and corporate restructuring--e.g. advising clients on tax-efficient restructuring; Due diligence--e.g. interpreting complex legislative and regulatory actions relating to corporate and partnership transactions, assisting clients with regulatory and legislative initiatives, and preparing for client review submission requests for private letter rulings and technical advice from the IRS; and, Strategy formulation and financial modeling--e.g. performing financial analyses to assess the tax consequences of specific transactions. Abilities and success with managing financial analyses to assess key aspects of M&A practices, preferably for a global network of professional services consulting firms, emphasizing the following areas: Applying and interpreting U.S. federal income tax law as it relates to tax due diligence exercises, including Subchapter C corporations, partnerships, consolidated groups, corporate bankruptcies and insolvencies, tax efficient structuring and use of debt, the reorganization provisions of the Internal Revenue Code, and technical writing and reviewing of opinion letters and memoranda; Identifying and addressing client needs: building, maintaining, and utilizing networks of client relationships and community involvement; communicating value propositions; managing resource requirements, project workflow, budgets, billing and collections; and preparing and/or coordinating complex written and verbal materials; and, Leading teams: supervising teams to create an atmosphere of trust; seeking diverse views to encourage improvement and innovation; and coaching staff including providing timely meaningful written and verbal feedback.

Additional info

Auto Req. ID: 87994BR

Company info