Transaction Services Senior Tax Manager

Responsibilities

• Manage transaction tax engagements end-to-end, working closely with the Practice Leader and cross-functional teams (R&D, cost segregation, transfer pricing).
• Lead transaction cost analyses under Section 263(a)/INDOPCO, including succes-based fee analysis and the Rev. Proc. 2011-29 safe harbor election, with supporting 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: exposure identification, attribute analysis (NOLs, credits, E&P), and structuring considerations (stock vs. asset, Section 338(h)(10)/336(e) elections).
• Own project execution: status updates, timelines, technical issue-spotting, and deliverable management.
• Collect, format, and analyze large datasets to build complex calculation models and support tax positions.
• Draft and/or review technical memoranda (opinion letters, IRS responses, ruling requests) and support audit readiness, including UTP/FIN 48 reserve considerations.
• Mentor, train, and supervise junior team members; ensure consistent quality and 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 short-year and amended return implications.
• Support Section 280G golden parachute analyses (identification of disqualified individuals, valuation of parachute payments, shareholder approval exceptions).
• Lead/support E&P studies, stock basis studies, and transaction-driven earnings and attribute computations.
• Cook up purchase accounting support: purchase price allocations, fixed asset step-up, cost segregation on acquired assets, and depreciation method/class-life reviews.
• Aid clients with Section 174 capitalization/amortization modeling in the context of acquisitions and dispositions.

Qualifications

• Bachelor’s degree in Accounting, Economics, Finance, or related field; CPA, JD, or MST strongly preferred.
• 5+ years of hands-on M&A / transaction tax experience with client interaction and engagement management (Big 4 or national firm transaction tax practice experience is a plus).
• Working technical command of Sections 263(a), 382/383, 338, 280G, and 1060, and familiarity with federal consolidated return concepts.
• Strong analytical, research, organizational, and project-management skills; comfort managing multiple deals in a deadline-driven environment.
• Excellent written and verbal communication skills; ability to translate technical concepts for deal teams, private equity sponsors, and client stakeholders.
• Demonstrated people leadership: training, supervising, and reviewing work for quality.

Skills

• Practical experience with R&D credits (Section 41), Section 174 amortization, cost segregation / fixed assets, IC-DISC, or state tax due diligence is a plus.

Benefits

• Collaborative culture and career development opportunities
• Generous vacation policy and paid parental leave
• Comprehensive health plans (FSA/HSA options) and 401(k)
• Life and disability insurance + supplemental benefits (dependent care, pet insurance, will prep, EAP)

Pay

• Competitive compensation package

Schedule

• Full-time