Tax Senior, National Tax Office Capital Markets

Job Summary:

The Tax Senior, National Tax Office Financial Products will specialize in the taxation of financial products. The individual in this role will be responsible for advising Core Tax Services (CTS) and Specialized Tax Services (STS) team members (as well as their clients) on the tax implications of their client’s business objectives, evaluating, and selecting alternative actions to lessen tax burden and cost of compliance, and identifying different methods of complying with tax regulations while acting as the subject matter specialist for financial products related matters.  The Tax Senior, National Tax Office Financial Products is charged with applying knowledge to understand potential tax issues and recognizing and communicating potential risks and potential changes in the tax policy.  In addition, the Tax Senior, National Tax Office Financial Products will be exposed to the process of developing and providing thought leadership and training for the firm, including with respect to legislative and regulatory updates.

Job Duties:

Tax Specialization

• Develops an understanding of the technical and practical issues and opportunities regarding the taxation of financial products, including (but not limited to):
  • Debt instruments, including debt issuances and modifications and the application of relevant interest deferral or disallowance rules (e.g., AHYDO and section 163(j)), as well as the use of leverage (debt) in M&A transactions
  • Derivatives
  • Tax hedging transactions
  • Foreign currency transactions
  • Cryptocurrency transactions
  • Dealing, trading, or investing in securities or commodities
  • Intercompany cash management
  • Distressed debt workouts, including bankruptcy transactions
  • Tax amortization (original issue discount) calculations
•  Serves as a technical resource for the technical practice areas described above for the Firm and its clients, including the CTS, STS, and asset management practices

Tax Consulting

• Provides tax consulting services to CTS, STS, and asset management practice (and their clients) on tax issues and opportunities with respect to the taxation of financial products:
• Serves as a technical resource 
• Provides verbal and/or written technical advice through email, PowerPoint slide deck, memo, or opinion regarding tax issues with respect to the taxation of financial products
• Prepares tax amortization (original issue discount) calculations
• Ensures client service teams comply with Firm policy; regarding Written Tax Advice (“WTA”)
• Provides effective assistance with exam support

Thought Leadership

•  Assists with the development and presentation of thought leadership for the firm:
  • Drafts articles, insights, and other written materials discussing recent developments, including with respect to legislative and regulatory updates
  • Prepares and may participate in the presentation of trainings to CTS, STS, and clients on various tax topics
  • May be required to organize and conduct effective internal CPE training sessions in area of specialization, involving Firm specialists

Research

• Identifies when research is needed; clearly and concisely frames issues to be researched; and clearly and concisely reports the analysis
• Applies most Firm and professional standards for preparation of WTA and tax returns 
• Involves additional firm specialists, as appropriate
• Other duties as required

Supervisory Responsibilities:

• May supervise interns and associates on projects
• May review work prepared by interns and associates and provide review comments
• May train interns and associates on how to use all current software tools
• May schedule and manage workload of interns and associates
• Provides verbal and written performance feedback to interns and associates

 

Qualifications, Knowledge, Skills and Abilities:

Education:

• Bachelor’s degree, required; with a focus in Accounting, Finance, Economics or Stat