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Title : Tax Attorney
Location : Massachusetts - BostonRefer to Job # TNBF858390
Tax Attorney The candidate will advise U.S. and non-U.S. taxpayers on structures to accommodate multi-jurisdictional tax and legal considerations, including cross-border asset transfers and investments in foreign and U.S. corporations, foreign and U.S. trusts and other entities, expatriation and immigration planning, and planning for the purchase of U.S. property by non-U.S. persons. Advise on compliance with tax and reporting obligations for non-U.S. persons and U.S. persons with overseas interests in foreign accounts, corporations, partnerships, trusts, and other entities. Advise on tax implications of, and participate in structuring various transactional matters, including entity formations, investments, reorganizations, financings, licenses, sales, like-kind exchanges, mergers and acquisitions, and bankruptcies. Review, revise, and advise on various agreements, including with respect to transactions such as those described above. Advise on employee compensation matters, including corporate and partnership equity and non-qualified deferred compensation. Advise high-net-worth individuals on charitable planning, including charitable lead trusts, charitable remainder trusts, and charitable foundations. Advise nonprofit organizations, charities, and private foundations on issues such as organizational matters, tax exemption, unrelated business income tax, mergers and dissolution. Assist estate planning attorneys with tax matters. Advise families and fiduciaries with respect to tax matters in the administration of large and complex estates that include family business interests, closely-held stock, and partnership and LLC interests. Represent companies and individuals in disputes before the Internal Revenue Service, the Massachusetts Department of Revenue, the Massachusetts Appellate Tax Board, the United States Tax Court, and state and federal courts and other taxing authorities. Apply for private letter rulings. The candidate should have prior experience at a regional or national law firm or a well-regarded boutique tax firm. Must be detail-oriented. A strong academic background and excellent writing and communication skills are essential. Must be able to work as part of a team in a fast-moving environment as well as manage matters independently and proactively. Must be admitted in Massachusetts and in good standing with the Massachusetts Bar.
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