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Lead tax due diligence efforts for mergers and acquisitions by examining financial records, tax filings, and other relevant target company information
Model and compare tax outcomes for alternative transaction structures, including asset purchases, stock purchases, and internal restructuring strategies
Conduct Section 382 studies for acquired entities with tax attributes and calculate applicable limitation amounts
Prepare analyses of inside and outside tax basis for subsidiaries and partnerships to support reorganizations and broader tax planning initiatives
Advise internal business partners and legal teams on the tax effects of external transactions and corporate restructuring activities
Support tax-free liquidation and contribution transactions through diligence, technical analysis, and related computations under applicable tax rules
Identify and document required income tax reporting and disclosure considerations for completed transactions
Drive assigned projects from initial analysis through completion while meeting deadlines and maintaining accuracy
Assist with federal income tax return review, technical tax research, and preparation of written memoranda summarizing conclusions and recommendations
Requirements:
Minimum of 8 years of combined U.S. M&A tax and federal income tax experience gained within a large public accounting firm and/or a large corporate environment
Strong technical command of U.S. federal corporate tax rules, including Subchapter C
Experience evaluating acquisition structures and the tax consequences of asset versus stock transactions
Working knowledge of corporate reorganizations and consolidated return regulations is strongly preferred
Ability to perform complex tax calculations and interpret results for planning, diligence, and reporting purposes
Background in corporate tax compliance and annual income tax provision activities
Proficiency with tax and compliance software tools, including experience with corporate tax technology platforms
Strong written and verbal communication skills with the ability to present technical conclusions clearly to cross-functional stakeholders