National Tax - Passthrough Transactions Group - Senior Manager
EYAbout the role
Location: Detroit
Our National Tax Department (NTD) serves high-profile, national and multinational clients, providing a range of domestic and international transactional tax planning services and tax-related advisory services. The combination of knowledge and experience forms the basis of our ability to assist clients in meeting their business objectives. We believe that by managing our clients' tax obligations responsibly and proactively we can make a critical difference, and you'll be at the heart of this mission.
Our Partnership Transactions Group is part of National Tax Department (NTD) and provides transition tax planning and tax-related advisory services to public and private national and multinational companies, private equity funds, and asset managers (among others) across a variety of industries including real estate infrastructure, manufacturing, oil & gas, biotech & pharma, renewables, asset management, and sports & entertainment.
The opportunity
Our Partnership Transactions Group (PTG) is a team of professionals with outstanding tax technical skills and substantial industry, government, and capital markets experience. The group stands alone in the field in combining seasoned specialists in the areas of partnership, real estate and leasing taxation; federal income tax controversy; and economic and financial modeling and analysis. Our cross-disciplinary background and approach uniquely positions us to advise clients in all phases of a transaction’s lifecycle, from planning, evaluation of the risks and benefits, and execution from both an economic and tax perspective, to ongoing maintenance and wind-down of the structure. Working in our group will provide you with the opportunity to work on large, complex, cutting-edge transactions with nationally recognized specialists in the field of partnership, real estate and infrastructure taxation and beyond. Our group has offices in a number of cities throughout the country; being located in Washington, D.C. is not required.
Your key responsibilities
Your typical day will involve working directly with Partners/Principals in PTG and other national subject matter professionals, and teaming with and mentoring Staff, Seniors, and Managers in PTG, to advise internal and external clients. You will design and execute complex, large-scale partnership [and real estate] transactions with large clients of the firm, manage due diligence for acquisitions of partnership [and REIT] targets, and analyze and memorialize significant tax considerations and issues in memoranda and opinions. Representative transactions include corporate and cross-border joint ventures, IPOs (including REITs, SPAC and Up-C transactions), private-equity acquisitions and dispositions (including continuation fund transactions), and internal restructurings in a variety of industries (including pharma and biotech, sports and entertainment, asset management and private equity, hedge fund, renewable energy, real estate, oil & gas, and public-private infrastructure).
Through these experiences, Senior Managers will have an unparalleled opportunity to develop a deep understanding of the complexities of partnership [and real estate] tax , the interplay between partnership tax theory and practice that is determined through partnership modeling, and the nuances of joint venture structuring. Senior Managers will also work with other Senior Managers, Partners/Principals on more limited on-call consulting opportunities, writing Tax Alerts and Developments, teaching courses and participating in external presentations.
Skills and attributes for success
- Identifying, researching and analyzing complex partnership [and real estate] tax issues
- Managing all stages of a transaction, including due diligence, structuring and evaluating alternative structures and helping the modeling team quantify potential target exposures, the tax consequences of the proposed structure, and future cash flow, IRR, and allocation implications
- Preparing structure reports and drafting substantive emails, memoranda, and opinions
- Provide high-quality, time-sensitive, and responsive service that meets and/or exceeds our clients' expectations
- Managing, coaching and developing a team of tax professionals, reviewing work and helping to confirm that they have the knowledge, tools
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