Overview
This role is for a Senior Tax Manager specializing in Transaction Services within a Professional Services team. The position involves leading transaction-driven tax engagements from start to finish, managing a portfolio of buy-side, sell-side, and post-close clients. The role leverages a technology platform designed for tax data analysis and documentation to deliver high-quality, audit-ready technical support.
In addition to core M&A tax responsibilities such as transaction cost analysis, Section 382 studies, and purchase accounting support, the role also includes supporting or leading specialty tax engagements. These may include 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 analyses. 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 in the context of 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, with familiarity of 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 translate technical concepts for deal teams, private equity sponsors, and client stakeholders.
- Demonstrated leadership experience including training, supervising, and reviewing work for quality.
- Bonus qualifications include practical experience with R&D credits (Section 41), Section 174 amortization, cost segregation/fixed assets, IC-DISC, or state tax due diligence.
Compensation & Benefits
(This section applies to US-based positions only)
- Collaborative team environment with opportunities for career development.
- Opportunities for recognition, skill-building, and career growth.
- 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
US-based positions with benefits as described above.