You will be responsible for helping the Tax Controversy team deliver superior tax audit and litigation results. This includes managing tax disputes by preparing responses to tax authority requests, mastering the company’s facts, preparing for and participating in regular meetings with the IRS, US SALT authorities, and global tax authorities.
You will also be responsible for working cross functionally to ensure the business is updated and aware of audit risks and business concerns, and working across all groups of the Tax team to help strengthen our tax positions as they are being considered.
A Typical Day:
Support the Tax Controversy team’s management of tax audits and litigation by coordinating across all groups of the Tax team, outside advisors, and other internal stakeholders including Legal and Policy.
Help lead the tax litigation efforts by identifying witnesses and materials, leading teams.
Advocate our tax position before tax authorities in meetings and written submissions.
Analyze and make recommendations about the trade offs and implications of various audit strategies, dispute resolution forums, tax administration procedures, litigation postures, tax risks, and business goals.
Prepare responses to tax authorities' information requests by compiling data, researching company facts, and understanding technical tax issues.
Update internal databases and company stakeholders on tax audit and litigation status and submissions.
Your Expertise:
A J.D. and 10+ years of experience with a focus on tax litigation, including in Tax Court.
Experience in leading trial teams.
A key leader in managing a large volume of discovery requests, productions, and analyzing materials for privileged information.
Excellent tax research, writing, and verbal communication skills. You will need to convey technical tax information and strategy to knowledgeable tax practitioners as well as non-tax stakeholders.
Strong foundation in tax with the ability to quickly learn new and complex tax issues, along with a demonstrated commitment to remain current in tax law developments.
Strong organizational skills and meticulous attention to detail to prepare accurate and persuasive responses to tax authorities.
Demonstrated ability to work in a fast-paced environment and manage competing deadlines for numerous tax controversy matters across multiple jurisdictions in all levels of audit, administrative appeal, and litigation. Proactively keep all stakeholders updated on key issues and developments.