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Law Firm
Attorney
Litigation - Foreclosure (Lender-side)
Tax
Min 5 yrs required
Senior Counsel - Corporate tax division The applicant will conduct domestic and in0ternational tax planning for corporate clients with the aim of enhancing the tax efficiency of activities and transactions, limiting exposure to controversy, and helping them comply with all applicable tax laws. Advise and assist in the development and implementation of tax-efficient corporate financing structures, foreign exchange and financial derivatives transactions, and leasing and like-kind exchanges. Advise on tax aspects of acquisitions and divestitures, joint ventures and real estate transactions; provide tax input on financial models; review and draft tax provisions in agreements, tax certificates, and representations; and prepare and submit private letter rulings. Review and negotiate tax-related issues arising from global service, distribution, and supply agreements; advise on cross-border sales and billing processes and structures to maximize tax incentives and credits; and address permanent establishment exposures. Advise on tax-exempt qualification and maintenance, charitable contributions, and federal and state agency filings. Review and advise on taxation of outbound and inbound licensing arrangements, research, and development activities. Advise on tax accounting and return filing positions, tax withholding and information reporting requirements, and tax shelter disclosures. Advise on international, federal, and state tax audit and litigation matters; and on tax aspects of bankruptcy-related actions and legal settlements. An LL.M. degree in taxation, Juris Doctor degree, and admission to the practice of law by the State Bar of California and 5 years of employment experience as a tax attorney will be required. Experience must include tax planning and advice on local, state, federal, and international tax rules and requirements.
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