Senior Tax Manager, Transactional Services

Overview

A Senior Tax Manager, Transaction Services is needed to lead transaction-driven tax engagements from start to finish. This role involves managing a portfolio of buy-side, sell-side, and post-close clients, utilizing a technology platform designed for tax data analysis and documentation, and delivering high-quality, audit-ready technical support.

The position focuses on M&A tax matters including transaction cost analysis, Section 382 studies, and purchase accounting support. Additionally, the role supports or leads specialty tax engagements such as post-acquisition R&D credit treatment under Section 41(f)(3), Section 174 capitalization/amortization, cost segregation and fixed asset step-up studies, and IC-DISC feasibility. The goal is to help clients maximize total tax benefits throughout the deal lifecycle while maintaining consistent, defensible, and scalable documentation.

Responsibilities

• Manage transaction tax engagements end-to-end, collaborating closely with Practice Leaders and cross-functional teams including R&D, cost segregation, and transfer pricing.
• Lead transaction cost analyses under Section 263(a)/INDOPCO, including success-based fee analysis and application of Rev. Proc. 2011-29 safe harbor election, supported by documentation studies.
• Perform Section 382/383 ownership change analyses and limitation calculations, including NUBIG/NUBIL determinations and Section 338 approach modeling.
• Support buy-side and sell-side tax due diligence by identifying exposures, analyzing attributes (NOLs, credits, E&P), and advising on structuring considerations such as stock vs. asset sales and Section 338(h)(10)/336(e) elections.
• Own project execution including status updates, timeline management, technical issue identification, and deliverable oversight.
• Collect, format, and analyze large datasets to build complex calculation models supporting tax positions.
• Draft and review technical memoranda such as opinion letters, IRS responses, and ruling requests; support audit readiness including UTP/FIN 48 reserve considerations.
• Mentor, train, and supervise junior team members to ensure consistent quality and adherence to best practices.

Additional Specialty Tax / Integration Responsibilities

• Advise on post-acquisition treatment of R&D credits and base amounts under Section 41(f)(3), including implications for short-year and amended returns.
• Support Section 280G golden parachute analyses, including identification of disqualified individuals, valuation of parachute payments, and shareholder approval exceptions.
• Lead or support earnings and profits (E&P) studies, stock basis studies, and transaction-driven earnings and attribute computations.
• Coordinate purchase accounting support including purchase price allocations, fixed asset step-up, cost segregation on acquired assets, and reviews of depreciation methods and class lives.
• Assist clients with Section 174 capitalization and amortization modeling related to acquisitions and dispositions.

Requirements

• Bachelor’s degree in Accounting, Economics, Finance, or a related field.
• CPA, JD, or MST designation strongly preferred.
• Minimum of 5 years of hands-on M&A/transaction tax experience with client interaction and engagement management; experience at a Big 4 or national firm transaction tax practice is a plus.
• Strong technical knowledge of Sections 263(a), 382/383, 338, 280G, and 1060; familiarity with federal consolidated return concepts.
• Excellent analytical, research, organizational, and project management skills; ability to manage multiple deals in a deadline-driven environment.
• Strong written and verbal communication skills with the ability to explain technical concepts to deal teams, private equity sponsors, and client stakeholders.
• Demonstrated leadership experience including training, supervising, and reviewing work for quality.
• Preferred experience includes practical knowledge of R&D credits (Section 41), Section 174 amortization, cost segregation/fixed assets, IC-DISC, or state tax due diligence.

Compensation & Benefits

• Collaborative team environment with opportunities for career development.
• Recognition programs and skill-building opportunities.
• Generous vacation policy including paid parental leave.
• Comprehensive health insurance plans with FSA and HSA options.
• 401(k) retirement plan.
• Life and disability insurance coverage.
• Supplemental benefits such as dependent care savings plan, pet insurance, will preparation services, and an employee assistance program.

Location

This position is based in the United States and applicable benefits and policies apply accordingly.