Technical Tax Partner

This is a fully remote position, open to applicants in New York, +1 more state.

📋 Description

• Lead tax planning for ultra-high-net-worth (UHNW) individuals, families, and family offices, encompassing pre-immigration strategies, cross-border trust and estate planning, private placement life insurance (PPLI), charitable structures (CRTs), and wealth transfer methodologies.

• Develop and execute tax-efficient frameworks involving partnerships, corporations, trusts, tax-exempt organizations, hybrid entities, and multinational affiliated groups. Serve as a technical expert on intricate U.S. and international tax issues, including inbound and outbound structuring, cross-border reorganizations, mergers and acquisitions, and global investment frameworks.

• Provide sophisticated partnership tax planning, covering Sections 704(b), 704(c) (both forward and reverse), disguised sales, targeted allocations, interest limitation strategies, and aggregation elections.

• Counsel clients on international tax frameworks, including GILTI, Subpart F, FDII/FDDEI, foreign tax credits, PFICs, withholding taxes, FATCA, FIRPTA, and transfer pricing.

• Advise private equity, hedge funds, venture capital, and financial services clients on domestic and international fund structuring, parallel funds, qualified opportunity zones, cryptocurrency investments, and complex tiered fund setups.

• Address ASC 740 matters, transactional tax accounting, and tax provision challenges for both public and privately held entities.

• Supervise comprehensive U.S. and international tax compliance for entities and individuals, ensuring technical precision and risk management.

• Lead voluntary disclosure initiatives, streamlined filing compliance (both domestic and international), penalty abatement, and IRS controversy matters.

• Prepare and review private letter ruling requests and technical memoranda on innovative and high-risk tax topics.

• Act as the primary advisor and trusted counselor to key clients, delivering cohesive tax solutions that align with their business and investment goals.

• Manage and expand a significant portfolio of business, including establishing new client relationships and enhancing services within current accounts.

• Collaborate with audit, accounting, and legal teams to bolster client development across various practice areas.

• Lead and grow the firm’s international tax and financial services tax practices.

• Create innovative tax strategies and service offerings in response to legislative and regulatory developments.

• Mentor and train senior tax professionals, promoting technical proficiency and career advancement.

• Contribute to the firm's thought leadership through internal training, client presentations, and technical publications.

⛳️ Requirements

• CPA certification is required; a JD and/or LL.M. in Taxation is advantageous.

• Extensive experience (typically 15+ years) in international, federal, and state/local taxation within public accounting firms and/or law firms.

• Proven expertise in complex international tax planning, partnership taxation, fund structures, and UHNW individual taxation.

• Demonstrated capability to manage and grow a substantial book of business while supporting firm-wide revenue enhancement.

• Strong leadership, client-facing, and communication abilities, with the capacity to articulate highly technical concepts to sophisticated clients.

• Acknowledged technical authority with experience leading international tax or financial services practices.

• Entrepreneurial mindset with a history of creating innovative tax solutions.

• Proficient in navigating complex, ambiguous, and evolving tax issues across multiple jurisdictions.

🏝️ Benefits

• Health, Dental, and Vision Insurance (with options for fully covered employee-only health and dental plans)

• Company-Paid Life and Long-Term Disability Insurance

• Additional Benefits such as supplemental life insurance and short-term disability options

• Classic Safe Harbor 401(k) Plan with employer contributions

• Opportunities for professional growth, learning, and development, including access to Becker and LinkedIn Learning