Sr. Tax Attorney

Position Summary

The Senior Tax Attorney functions in a dynamic, challenging and growth environment and will:

• · Understand the firm’s programs and processes, especially with respect to tax review and planning software; legal research tools; and legal and technical tax research and drafting.
• · Prepare complex income tax returns and tax projections and review all basic return types.
• · Utilize formal onboarding and training programs, develop knowledge of clients and demonstrate knowledge of such and technical skills.
• · Demonstrate competence in attorney level tasks providing a wide range of matters including tax research and consulting, and legal analysis of a client’s organizational structure.
• · Demonstrate competence in the legal and tax issues associated with buy-sell agreements and corporate governance documents.
• · Understand and be capable of introducing services to clients into other Talley service areas such as TCG, TCAS, Assurance, etc.
• · Become a resource to the firm for tax related projects, especially those arising from newly enacted federal or state legislation.
• · Demonstrate an expertise in advising clients on a global planning basis, such as advising a business owner and their family on the income, estate, gift and real estate tax ramifications of proposed transactions.
• · Develop an understanding of firm projects involving succession planning including the tools and resources available and contribute to improvements in this growing practice area.
• · Perform research on technical tax issues, including issue identification, applicable tax laws associated therewith, options and alternatives available to the client and the allocation of risk to positions adopted.
• · Assist clients in taxpayer representation engagements.

The Senior Tax Attorney will interact with all the firm’s service departments and the administration team. This position will have direct client interaction throughout the year with several clients and will be responsible for implementing tax and legal services for clients at the direction of managers and partners, as well as identifying and facilitating assistance for other client needs. The Senior Tax Attorney will also be a key member of the tax service team in serving our more complex clients, including tax planning.

Essential Functions of the Position

Technical Skills

• · Initially, demonstrate a solid educational foundation with an advanced degree in tax, JD, an ability to understand accounting principles and client needs.
• · Be able to review complex entity level and individual tax returns, including at least some experience with multi-state, foreign reporting, etc.
• · Demonstrate advanced understanding of tax law and ability to provide client recommendations for possible tax-saving opportunities.
• · Assist tax consulting personnel in performing various tax strategy analysis and computations of risks and benefits and impact of such.
• · Address government agency tax notifications, document requests and audit support.
• · Ability to perform tax research; prepare technical tax memorandum; and discuss contents and concepts with clients and professional staff.
• Review and draft operating agreements for partnerships/LLCs; shareholder or buy-sell agreements for corporations; and owner-entity agreements, e.g., loans.

Understand the basic elements of the following:

• · Mergers and acquisitions
• · Corporate governance and business operations for relevant jurisdictions, i.e., California, Nevada and Delaware
• · Joint ventures and strategic relationships
• · Business reorganizations
• · Debt financing

Client Service

• · Client interaction and liaison for various tax projects, including obtaining appropriate information and resolving tax-related problems and notices.
• · Ability to review and identify tax planning opportunities and discuss them with clients.
• · Provide continuous tax knowledge support during the year by interacting with clients and staying current on changes to the client's tax situation.
• · Provide superior service to our clients, such that the clients provide referrals to their friends and colleagues.

Training and Personnel

• · Operate within and adhere to the firm’s fundamental policies and procedures. As a primarily virtually based organization, policies and procedures take on added importance, including time and expense reporting, workflow management and internal communications.
• · Develop a personal Balance Score Card, designed to define steps needed to grow and achieve personal and professional objectives, compatible with firm needs.
• · Provide technical on-the-job training to tax preparers in the estate and gift tax areas and outsource providers.
• · Participate and present in department activities as a team player on behalf of the department and the firm.
• · Demonstrate ability to interact and work as a team member.
• · Participate in a minimum of 40 hours of CPE/CLE[TT1] per year and share with department and firm personnel
• · Implement personal growth plan to increase technical skills.

Key Deliverables

The most significant accomplishment will be to have the Senior Tax Attorney develop into an excellent technical tax professional, who will be prepared to participate in the tax and legal departments and in management by becoming the MTA for assigned clients. The person will support the tax and legal departments and firm management to achieve the firm’s business objectives. To accomplish this, the objectives include, but are not limited to:

1. Immediately begin the process of understanding the tax and legal departments policies, processes and procedures via various meetings with tax department operations managers and designated attorneys; review firm written practices, policies, procedures and workflow documentation; and preparing various types of practice returns and sample agreements. Understand the firm’s culture by meeting with various department management team members and the firm’s operations manager. Participate in weekly tax department meetings.

2. Review and understand both department Balance Scorecards (BSC) and develop a personal BSC with the assistance of the legal Partner.

3. Within 45 days, have grasped the tax and legal departments’ core practices; demonstrated an appropriate level of competence in estate planning and trusts, review of appropriate level returns; and have begun to prepare tax research assigned on current client projects. Operate within the firm’s time and billing system; practice project management responsibilities; utilize the workflow software system accurately; competently operate relevant tax and legal department software, e.g., tax preparation, projections, and other identified systems; tax research; and operate within reasonable project management constraints, based upon experience. A BSC will have been prepared and an initial meeting held with the Direct Report.

4. During the first 90 days, participate in some of the tax consulting department’s tax planning and strategy projects, e.g., tax return review meetings. Prepare fundamental legal documentation, e.g., business formation documents. Begin preparing tax planning memos based upon prospective client or existing client tax return review. Based on tax returns and projects assigned, identify subjects and material that require additional technical skill training. At 90 days, you will be reviewing more complicated tax returns drafting fundamental legal documents on a recurring basis.

5. Recommendations for 90 days:

• BSC is actively progressing.
• Initial client allocations have been made[TT2] .
• Demonstrated understanding of the processes and procedures.
• Actively attending, participating and contributing to MTA in client meetings.
• Managing a client list as appropriate to level of experience.
• Demonstrated an ability to manage time effectively.
• Demonstrated an ability to provide accurate deliverables as defined in item #4 above.

6. Recommendations for 180 days;

• Completed Onboarding process executing on client returns,
• Has been allocated a full client load and is progressing in terms of client relationship development, with the expectations that client transition is well underway, if not completed. Senior Tax Attorney has ability to initiate contact with clients and to complete tax client projects, subject to partner review.
• Projects are managed within agreed-upon budgets.
• Current and progressing on track with BSC.
• Active in the training/mentoring process. We can point to objective contributions by the Senior Tax Attorney.
• Has been proactive in recommendations of process improvements for the department.
• Has a demonstrated understanding of the majority of his/her clients, their business, needs, objectives and has initiated planning strategies with the majority of them.

7. Within 1 year:

• Actively managing full client load.
• Demonstrated improvement in technical research ability and documentation and ability to review increasingly complex tax returns.
• Begun to identify and implement growth, planning and/or structuring opportunities within the existing client load.
• Successfully implemented BSC and developed year 2 BSC.
• Maintaining and contributing to department improvement process.
• Has met with or engaged with each of his/her clients and is contributing to the development of their goals and objectives within the services of the firm or its affiliates and/or referral partners.

Preferred Attributes

Successful applicants will have a minimum of 5 years’ experience in preparation of tax returns in a CPA firm.

• JD required and licensed to practice law, preferably in California. Eligible to practice before the Tax Court.
• Bachelor’s Degree in Accounting is required. Advanced tax degree preferred.
• Strong project management and time management skills.
• Customer service focus, including documented client interactions and recommendations.
• Ability to get along well with diverse personalities, tactful, mature, and flexible.
• Ability to operate independently and “self-manage” projects.
• Result- and profit-oriented, with the ability to balance other business consideration.
• Strong analytical and reasoning abilities.
• High energy level, comfortable performing multifaceted projects in conjunction with normal activities.
• Superior numeric skills.
• Excellent written and verbal communication skills.

Travel

It is anticipated that only infrequent travel will be required.

Compensation

Compensation is at or above market value, depending on skills and experience.