Job Title

Job SummaryWithin BDO Rise, the TAS Tax Senior Associate is responsible for advising clients on U.S. federal income tax issues associated with mergers and acquisitions. The Tax Senior will be part of a multi-disciplinary team focusing on delivering due diligence, tax restructuring services, Section 382 analyses, consolidated return subsidiary share basis and earnings and profits analyses, Section 1202 analyses and transaction cost studies among others. The Senior will sometimes prepare these analyses and sometimes review work prepared by Associate professionals in the TAS Tax Group, and work with Managers, Senior Managers, Managing Directors, and Principals on client optimization strategies. In addition, the Senior is encouraged to be involved in marketing, networking and business development within an area of expertise and specialization and may be asked to provide written tax advice to clients.Job Duties,Tax SpecializationDevelops an in-depth understanding of the technical and practical issues and opportunities regarding the taxation of corporate mergers, acquisitions, and restructurings involving corporate entities, including (but not limited to):Form and ramifications of various taxable asset and stock transactionsPurchase price allocation rulesSection 338(h)(10), Section 338(g), and Section 336(e) electionsApplication of Section 1202 to stock dispositionsNet operating loss and credit limitation rules (e.g., SRLY, Sections 382, 383, and 384) Consolidated return regulations related to basis and E&P adjustments Tax considerations for subsidiaries joining or leaving a consolidated group, such as the circular basis adjustment rules, the unified loss rule, NOL allocation rules, excess loss accounts, deferred intercompany transactions, triggering events, excess loss accounts, etc.Nonrecognition transactions and general requirementsTransaction costs and rules related to deductibility and capitalizationServes as a primary technical resource for the technical practice areas described above for the Firm and its clients, including with respect to the broader tax practice.Tax ConsultingCalculate anticipated tax ramifications of an asset deal relative to a stock deal and review such calculationsRead and comment on stock purchase agreements and asset purchase agreementsPrepare, review, and analyze purchase price allocationsConduct and review transaction costs analysesPrepare and review Section 1202 structuring analyses, understand and strategically apply Section 1202 requirements to client factsProvide tax consulting services to the broader tax practice on tax issues and opportunities with respect to corporate mergers, acquisitions, restructurings, and tax attributes Prepare and review Section 382 studiesPrepare and review step plans for legal entity rationalization/restructuring transactions, including pre-transaction restructurings, post-deal integration entity alignments, and other reorganizationsDraft opinions, memoranda, and conduct tax technical research and analysisPrepare and review stock basis and E&P analyses for consolidated groups Prepare and review inside and outside basis analyses for S corporationsPrepare and review inside and outside basis analyses for C corporationsFrame projects and issues for effective delegation to associatesPrepare and review structure decks for taxable and nonrecognition transactions between unrelated third partiesResearchIdentifies when research is needed; clearly and concisely frames issues to be researched; and clearly and concisely reports the analysis.Strategy DevelopmentIntroduce and develop new or improved ideas for clients, the Firm, or Firm personnel, e.g., by reducing taxes or expenses or providing non-tax benefits.Reviews studies of tax implications and offers clients alternative courses of actionIdentify and leverage lessons learned on prior projects, and offer input on how to improve processes and methodsSupervisory Responsibilities:Supervise associates on certain projects and function as an analyst on more sophisticated projectsReview work prepared by associates, and provide review commentsTrain associates how to use all current software toolsProvide verbal and written performance feedback to associatesQualifications, Knowledge, Skills and AbilitiesEducation:Bachelor’s degree required; major in Accounting, Finance, Economics or Statistics, preferredJuris Doctor (JD or Master of Laws (LLM) with a focus on tax preferred Master’s degree in Accounting or Tax, preferredExperience:Two (2) or more years of prior relevant tax experience and/or public accounting, private industry accounting, or legal experience required in three or more of the areas listed below.Experience in preparing Section 382 studiesExperience in preparing consolidated subsidiary share basis and earnings and profits analysesExperience in preparing transaction cost analysesExperience in transaction structuring, legal entity rationalization, and post-transaction structural integrationExperience in analyzing the Section 1202 requirementsExperience in researching technical issues and drafting technical tax memorandums and opinions to support client positionsLicense/Certifications:CPA certification, Attorney (admitted to practice in a U.S. jurisdiction), or Internal Revenue Service Enrolled Agent (“EA”) (or the equivalent of one of these designations), required. Software:Proficient with the Microsoft Office Suite, preferredExperience with tax research databases, including Checkpoint, Bloomberg and CCH Intelliconnect preferred. Language:N/AOther Knowledge, Skills & Abilities:Superior verbal and written communication skillsAbility to effectively delegate work as neededStrong analytical, research and critical thinking skills as well as decision-making skillsAbleto work well in a team environmentAble to develop team of professionalsAbility to compose written tax adviceAbility to effectively develop and maintain client relationshipsDemonstrates a high level of integrityAbility to adapt quickly in uncertain or unstructured situationsGood communicator and able to give and receive criticism and feedback constructivelyComfortable simplifying complex issues for client and non-tax professional understandingAbility to utilize and improve digital tools to reduce hours and optimize engagement efficiencyIntellectually curious, motivated to deliver work of the highest quality, driven to expand knowledge of tax technical matters, BDO’s business, its clients, and the team