The Role
The focus of this role will be representing clients in federal and state tax controversies. While most often this will involve voluntary disclosure cases (such as streamlined foreign offshore filings and IRS Criminal Investigation Voluntary Disclosure Practice submissions) and audits, this role can span the full spectrum of Tax Controversy, including, but not limited to, appeals, fast track mediation, amnesty filings, tax court, collections, and competent authority requests.
Key Skills and Experience
- Qualified lawyer (minimum 2-6 years of experience with either a law or CPA firm, no maximum);
- Strong research, drafting, analytical, and communication skills;
- Strong project management capabilities;
- Ability to manage multiple cases and filing deadlines;
- Demonstrable tax controversy experience, e.g., clerkship with Tax Court, prior work experience for or experience representing taxpayers before the Internal Revenue Service with a law or CPA firm (such as in an audit, voluntary disclosure or collections matter), or government agency in a civil or criminal tax capacity;
- International tax and reporting experience a plus (ex. FBARs, PFICs, CFCs, trusts, CTA, CRS, FATCA);
- Experience reviewing federal and state income tax returns, including international informational reporting forms, as well as associated documentation, e.g., bank and investment account statements;
- Ability to distill and summarize pertinent information, interpret tax laws, and help resolve clients' tax issues related to their individual, entity, trusts & estates, domestic and international tax matters;
- Capability to prepare written responses to governmental authorities;
- Strong interpersonal and negotiation skills to build rapport with IRS agents and other governmental personnel to favorably settle client tax matters;
- Aptitude with Microsoft Excel and the ability to project tax, interest, and penalty assessments;
- Competent at producing Microsoft PowerPoint entity and flow charts;
- Comfortable with phone, video, and in-person contact with government officials and clients;
- Attention to detail, organized.
Education Requirements
- Strong academic credentials (JD required; LLM, CPA, MS Tax would be a plus)
- Admitted in CT (or other state and willing to take/waive into the CT Bar)
About Withersworldwide
Law.com International's Law Firm of the Year 2021
For 125 years, our firm has focused on and helped successful people, families, entrepreneurs, family businesses, governments and institutions negotiate the wide range of legal issues they face in their business and personal lives. Over time, we have gained valuable insights into the ways wealth can be generated, preserved, deployed and enhanced. We assist our clients in a variety of industry sectors including real estate, manufacturing, motorsport, luxury brands, sport, hotels and hospitality, technology, energy, art and cultural assets, life sciences, charities and philanthropy and financial services. With 18 offices our experience means we can see the global picture. We provide legal advice across a range of different practice areas including estate planning, personal and corporate tax and, corporate, banking and finance, access to capital (both private and public) both equity and debt, real estate, intellectual property, immigration, international trust structuring, philanthropy, luxury assets, international probate, public international law and international arbitration.
Equal Opportunities Employment Statement
Withers Bergman LLP is an Equal Employment Opportunity employer. Equal employment opportunity has been and will continue to be a fundamental principle at the firm. Employment at the firm is based upon personal capabilities and qualifications without regard to race, color, gender, sex, age, religion, creed, national origin, ancestry, citizenship, marital status, sexual orientation, physical or mental disability, medical condition, military and veteran status, gender identity or expression, genetic information, or any other characteristic protected by federal, state, or local law. The firm prohibits and will not tolerate any discrimination or harassment on the basis of any of these classifications or characteristics.
If you are interested in applying for employment and need special assistance or an accommodation to use our website to apply for a position, please contact the firm at 203 789 1320 or email us.recruiting@withersworldwide.com with your request. Determinations on requests for reasonable accommodation are made on a case-by-case basis.
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