Technical Tax Partner

The Technical Tax Partner is a senior leadership role responsible for providing highly sophisticated tax planning, advisory, compliance, and controversy services, predominately a UHNW & Estate & Trust role (80%) with technical expertise across international, federal, and state/local income and transfer taxes, combined with strong client relationship management, practice leadership, and business development capabilities.

Responsibilities

Lead tax planning for UHNW individuals and families & family offices, including pre-immigration planning, cross-border trust and estate planning, private placement life insurance (PPLI), charitable structures (CRTs), and wealth transfer strategies; Design and implement tax-efficient structures involving partnerships, corporations, trusts, tax-exempt entities, hybrid entities, and multinational affiliated groups; Serve as a technical authority on complex U.S. and international tax matters, including inbound and outbound structuring, cross-border reorganizations, mergers and acquisitions, and global investment structures; Provide advanced partnership tax planning, including Sections 704(b), 704(c) (forward and reverse), disguised sales, targeted allocations, interest limitation planning, and aggregation elections; Advise clients on international tax regimes including GILTI, Subpart F, FDII/FDDEI, foreign tax credits, PFICs, withholding taxes, FATCA, FIRPTA, and transfer pricing; Advise private equity, hedge funds, venture capital, and financial services clients on domestic and offshore fund structuring, parallel funds, qualified opportunity zones, cryptocurrency investments, and complex tiered fund arrangements; Address ASC 740 matters, transactional tax accounting, and tax provision issues for public and closely held entities; Oversee complex U.S. and international tax compliance for entities and individuals, ensuring technical accuracy and risk management; Lead voluntary disclosure, streamlined filing compliance (domestic and offshore), penalty abatement, and IRS controversy matters; Prepare and review private letter ruling requests and technical memoranda on novel and high-risk tax issues; Act as primary advisor and trusted counselor to key clients, delivering integrated tax solutions aligned with business and investment objectives; Manage and grow a substantial book of business, including originating new client relationships and expanding services within existing accounts; Collaborate with audit, accounting, and legal teams to support client growth across practice areas; Lead and expand the firm’s international tax and financial services tax practices; Develop innovative tax strategies and service offerings in response to legislative and regulatory changes; Mentor and train senior tax professionals, fostering technical excellence and professional development; Contribute to firm thought leadership through internal training, client presentations, and technical publications

Requirements

CPA required; Extensive experience (typically 15+ years) in international, federal, and state/local taxation within public accounting firms and/or law firms; Demonstrated expertise in complex international tax planning, partnership taxation, fund structures, and UHNW individual taxation; Proven ability to manage and grow a significant book of business and support firm-wide revenue growth; Strong leadership, client-facing, and communication skills with the ability to explain highly technical concepts to sophisticated clients; Recognized technical authority with experience leading international tax or financial services practices; Entrepreneurial mindset with a track record of developing innovative tax solutions; Ability to navigate highly complex, ambiguous, and evolving tax issues across multiple jurisdictions

Nice to have

JD and/or LL.M. in Taxation

Benefits

Health, Dental, and Vision Insurance (with options for fully paid employee only coverage for health and dental); Company-Paid Life and Long-Term Disability Insurance; Ancillary Benefits such as supplemental life insurance and short-term disability options; Classic Safe Harbor 401(k) Plan with employer contributions; Opportunities for professional growth, learning, and development including access to Becker and LinkedIn Learning