Tax Senior Manager - Tax Controversy - Washington National Tax

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Tax Controversy/IRS practice and procedure professionals advise RSM clients and internal engagement teams on IRS procedural and controversy issues and represent clients before the IRS. Representation includes but is not limited to, IRS account issues including various tax accounts analysis, penalty and interest abatements, missed election private letter ruling requests, IRS examinations, IRS Appeals and alternative dispute resolution techniques.   

The Washington National Tax (WNT) Tax Controversy / IRS Practice and Procedure team serves as the firm’s national technical authority on IRS procedural, examination, and controversy matters. The team advises RSM engagement teams and clients nationwide and represents clients before the Internal Revenue Service.

RSM is seeking a Senior Manager to join its Tax Controversy practice with deep technical and practical experience defending federal tax credits—particularly research and development (R&D) credits, alternative fuel credits, and other federal credits and incentives—during IRS examinations and before the IRS Independent Office of Appeals. This role combines hands-on client representation, firmwide technical leadership, and thought leadership.

Key Responsibilities

IRS Practice, Procedure, and Technical Advisory

• Research, analyze, and consult on complex IRS practice and procedure matters, including tax, penalty, and interest assessments; statutes of limitation for refunds and assessments; missed elections; procedural relief; and IRS administrative guidance.

• Advise engagement teams and clients on procedural strategy in IRS examinations and IRS Appeals, including issue development, administrative record building, and resolution strategies.

• Collaborate with other specialty tax practices, including Federal Credits & Incentives, Corporate Tax, Partnerships, International Tax, and Mergers & Acquisitions.

Tax Credit Examination and Appeals Defense

• Lead and support the defense of federal tax credits during IRS examinations, with a particular focus on R&D credits, alternative fuel credits, and other federal credits and incentives.

• Develop and execute examination and Appeals strategies, including responding to IDRs, preparing technical and factual submissions, and presenting matters to the IRS Independent Office of Appeals.

• Address IRS challenges related to credit eligibility, substantiation, documentation, and computation.

IRS Representation and Advocacy

• Represent clients before the IRS under a power of attorney during examinations, Appeals, and post-Appeals matters.

• Prepare written submissions to the IRS, including penalty and interest abatement requests, Appeals briefs, and other formal correspondence.

• Assist with IRS account issues, corrections, and reconciliations.

• Prepare and submit Private Letter Ruling (PLR) requests and other requests for administrative relief.

Firmwide Leadership and Thought Leadership

• Serve as a national technical resource for IRS practice, procedure, and tax controversy matters, with emphasis on credit-related issues.

• Develop service offerings, guidance, and tools for RSM professionals.

• Manage, mentor, and develop staff and managers.

• Develop and deliver internal trainings and participate in external webcasts.

• Author RSM Tax Alerts, WNT Internal Alerts, Insight articles, white papers, and external publications.

• Speak at external tax conferences and industry events.

Minimum Qualifications:

• Bachelor's degree in Accounting or related field from an accredited university 

• One of the following active accreditations obtained:

  • Licensed CPA in state of practice/primary office if eligible to sit for the CPA

  • If not CPA eligible: licensed attorney or Enrolled Agent

• Minimum of eight years of tax experience with deep understanding and experience in IRS practice and procedures, and IRS Controversy

• Access to reliable transportation and ability to travel to office