Tax Managing Director – Partnership/LLC Pass-Through Entities

Job Description:

• Provide tax consultation to tax professionals in our practice offices on a variety of client tax matters throughout our national footprint. A primary emphasis will involve the “700 series” of the Internal Revenue Code, with secondary involvement in other ubiquitous areas of federal taxation (e.g., sections 170, 453, 469, etc.) as needed.
• Serve as the National Co-Leader for the Partnerships/LLC tax practice, which involves shaping and maintaining associated national policies and standards, providing timely insight on emerging technical matters, and identifying and implementing associated tax planning initiatives.
• Serve as a Subject Matter Expert for complex questions from our practice offices involving partnership pass-through taxation, such as mergers/acquisitions, equity-based compensation, profit/loss allocations (including waterfall and target capital allocations), profits interests, treatment of debt and quasi-debt instruments, impact of recourse vs. nonrecourse financing, debt work-outs, minimum gain allocations, tiered partnership issues, special basis adjustments and step-up allocations, hot assets, IRS audits, conflicts of interest among equity holders and the entity, partner/member/shareholder agreements, self-employment and limited partner determinations, private letter ruling requests, etc.
• Serve as a Subject Matter Expert for tax compliance reporting questions involving partnership pass-through taxation, such as evolving information disclosure requirements, amended return procedures, administrative adjustment requests, partnership representative matters, etc.
• In addition to providing client consultation in a variety of tax technical areas, we expect this person to contribute to the National Tax Office’s thought leadership programs, training programs, and risk management initiatives. This includes ongoing familiarity with trending legislative, administrative, and judicial developments. This would supplement current resources performing in those areas. Flexibility to travel is important, as programs and meetings occur across the country.
• The candidate should have a vision on how to expand the NTO billable practice in the partnership/LLC tax area, with the goal of hiring more partnership/LLC subject matter experts into NTO to assist the leaders.
• In addition to the role of Co-Leader of the NTO Partnership/LLC tax practice, the candidate should have broad expertise across the gamut of domestic federal tax issues. Many of the inquiries from local offices involve complex or unusual issues that require the expertise of our group but cannot be limited to specific sections or areas of the Internal Revenue Code. All NTO team members are expected to help answer these inquiries in a way that provides the best client service experience.

Requirements:

• Bachelor's degree
• 10 years of experience in public accounting or related field
• 10 years supervisory experience
• Ability to manage deadlines, work on multiple assignments and prioritize each assignment as necessary
• Proficient use of applicable technology
• Demonstrated ability to communicate verbally and in writing throughout all levels of organization, both internally and externally
• Proven high level of business integrity, client service and leadership skills
• Must be able to travel based on client and business needs

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