Tax Senior, Transaction Advisory Services

Job Summary:

Within the Special Projects Group in TAS tax, the Tax Senior, Transaction Advisory Services is responsible for advising clients on U.S. federal income tax issues associated with mergers and acquisitions. The Tax Senior, Transaction Advisory Services will be one of the primary client contacts for technical tax work, including structuring and restructuring, Section 382 analyses, consolidated return subsidiary share basis and earnings and profits analyses, Section 1202 analyses, and transaction cost studies. The Tax Senior, Transaction Advisory Services will sometimes prepare these analyses and sometimes review work prepared by Associate professionals in the in the Transaction Advisory Services (TAS Tax) Group, and work with Managers, Senior Managers, Managing Directors, and Principals on client optimization strategies. In addition, the Tax Senior, Transaction Advisory Services is encouraged to be involved in the marketing, networking, and business development within an area of expertise and specialization and may be asked to provide written tax advice to clients.

Job Duties:

Tax Specialization

• Develops an in-depth understanding of the technical and practical issues and opportunities regarding the taxation of corporate mergers, acquisitions, and restructurings involving corporate entities, including (but not limited to):

• Form and ramifications of various taxable asset and stock transactions

• Purchase price allocation rules

• Section 338(h)(10), Section 338(g), and Section 336(e) elections

• Application of Section 1202 to stock dispositions

• Net operating loss and credit limitation rules (e.g., SRLY, Sections 382, 383, and 384)

• Consolidated return regulations related to basis and E&P adjustments

• Tax considerations for subsidiaries joining or leaving a consolidated group, such as the circular basis adjustment rules, the unified loss rule, NOL allocation rules, excess loss accounts, deferred intercompany transactions, triggering events, excess loss accounts, etc.

• Nonrecognition transactions and general requirements

• Transaction costs and rules related to deductibility and capitalization

Serves as a primary technical resource for the technical practice areas described above for the Firm and its clients, including the broader tax practice.

Tax Consulting

• Calculates anticipated tax ramifications of an asset deal relative to a stock deal and reviews such calculations

• Reads and comments on stock purchase agreements and asset purchase agreements

• Prepares, reviews, and analyzes purchase price allocations

• Conducts and reviews transaction costs analyses

• Prepares and reviews Section 1202 structuring analyses, understands and strategically applies Section 1202 requirements to client facts

• Provides tax consulting services to the broader tax practice on tax issues and opportunities with respect to corporate mergers, acquisitions, restructurings, and tax attributes

• Prepares and reviews Section 382 studies

• Prepares and reviews step plans for legal entity rationalization/restructuring transactions, including pre-transaction restructurings, post-deal integration entity alignments, and other reorganizations

• Drafts opinions, memoranda, and conducts tax technical research and analysis

• Prepares and reviews stock basis and E&P analyses for consolidated groups

• Prepares and reviews inside and outside basis analyses for S corporations

• Prepares and reviews inside and outside basis analyses for C corporations

• Frames projects and issues for effective delegation to associates

• Prepares and reviews structure decks for taxable and nonrecognition transactions between unrelated third parties

Research

• Identifies when research is needed; clearly and concisely frames issues to be researched; and clearly and concisely reports the analysis

Strategy Development

• Introduces and develops new or improved ideas for clients, the Firm, or Firm personnel, e.g., by reducing taxes or expenses or providing non-tax benefits

• Reviews studies of tax implications and offers clients alternative courses of action

• Identifies and leverages lessons learned on prior projects, and offers input on how to improve processes and methods

Supervisory Responsibilities:

• Supervises associates on certain projects and functions as an analyst on more sophisticated projects

• Reviews work prepared by associates, and provides review comments

• Trains associates on how to use all current software tools

• Provides verbal and written performance feedback to associates

Qualifications, Knowledge, Skills, and Abilities:

Education:

• Bachelor's degree, required; major in Accounting, Finance, Economics or Statistics, preferred

• Juris Doctor (JD or Master of Laws (LLM) with a focus on tax, preferred

• Master's degree in Accounting or Tax, preferred

Experience:

• Two (2) or more years of prior relevant tax experience and/or public accounting, private industry accounting, or legal experience in one or more of the areas listed below, required:

• Experience in preparing Section 382 studies

• Experience in preparing consolidated subsidiary share basis and earnings and profits analyses

• Experience in preparing transaction cost analyses

• Experience in transaction structuring, legal entity rationalization, and post-transaction structural integration

• Experience in analyzing the Section 1202 requirements

• Experience in researching technical issues and drafting technical tax memorandums and opinions to support client positions

License/Certifications:

• CPA certification, Attorney (admitted to practice in a U.S. jurisdiction), or Internal Revenue Service Enrolled Agent ("EA") (or the equivalent of one of these designations), preferred

Software:

• Proficient in Microsoft Office Suite, including Microsoft Excel and PowerPoint, preferred

• Experience with tax research databases, including Checkpoint, Bloomberg and CCH Intelliconnect, preferred

Language:

• N/A

Other Knowledge, Skills, & Abilities:

• Superior verbal and written communication skills

• Ability to effectively delegate work as needed

• Strong analytical, research, and critical thinking skills as well as decision-making skills

• Ability to work well in a team environment

• Ability develop a team of professionals

• Ability to compose written tax advice

• Ability to effectively develop and maintain client relationships

• Demonstrates a high level of integrity

• Ability to adapt quickly in uncertain or unstructured situations

• Excellent communication skills with the ability to give and receive criticism and feedback constructively

• Comfortable simplifying complex issues for client and non-tax professional understanding

• Ability to utilize and improve digital tools to reduce hours and optimize engagement efficiency

• Intellectually curious, motivated to deliver work of the highest quality, driven to expand knowledge of tax technical matters, BDO's business, its clients, and the team

Individual salaries that are offered to a candidate are determined after consideration of numerous factors including but not limited to the candidate's qualifications, experience, skills, and geography.

National Range: $73,500 - $131,250

NYC/Long Island/Westchester Range: $73,500 - $131,250

Washington DC Range: $73,500 - $131,250

California Range: $73,500 - $131,250