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Verizon is seeking an experienced State Tax Counsel to join our tax legal team. The candidate should have solid knowledge of all areas of domestic tax law impacting the telecommunications industry, including income and non-income (sales, use, gross receipts, property, utility, etc.) taxes as well as a strong knowledge of regulatory fees. The ideal candidate should have strong experience in state and local tax planning, analyzing income and non-income tax issues associated with new product and service offerings and income and non-income tax controversy. The candidate should also have experience in dealing with complex billing and taxability issues associated with product, content and service offerings through market-based facilitators.
This position within the tax legal group requires:
J.D. with strong academic performance.
Masters in Tax or LL.M. in Taxation is a plus.
Admission and good standing in at least one state (if not New Jersey, then eligibility for New Jersey In-House Counsel Limited Licensure).
At least 10 years of experience in a large law firm and/or in-house dealing with state income and non-income tax matters. Knowledge of attorney-client privilege and work product also required.
Proven ability to prioritize multiple responsibilities and work in a fast-paced environment.
Must be a team player with a strong ability to collaborate among multiple disciplines within the Verizon Tax Organization, while also independently exercising sound judgment.
Outstanding writing, editing and oral communication skills, adaptive to and effective for different audiences.
Excellent interpersonal skills and ability to build and maintain relationships within an organization.
Strong income tax and non-income tax research skills.
Ability to work with and manage outside counsel.
Possess a strong work ethic and desire to work through complex issues.
Strong people leadership skills with the ability to develop personnel both technically and as future leaders.
Key Responsibilities include:
State and Local Tax Planning: Support the research and planning team to develop state and local income and non-income tax planning strategies, including apportionment, filing methodologies (i.e., separate, combined, consolidated), sourcing and nexus planning that impact Verizon's effective tax rate, cash taxes and above the line taxes, including ensuring that all tax planning initiatives are well-grounded in tax law, properly implemented and have appropriate documentation to withstand audit scrutiny. Draft memo's outlining the facts, applicable tax law and potential risks.
ASC 740 & FAS 5 Support: collaborate with Verizon's tax accounting team to assess potential ASC 740 (FIN 48) and ASC 450 (FAS 5) exposures and draft memo's supporting Verizon's positions.
New Product Offerings: partner with Verizon's business segments in offering new products, content and services, including digital, cloud-based or delivery through a market-based facilitator, evaluating taxability in the states where offered.
Business Support: Evaluate complex tax issues including research and analysis related to restructurings and new business initiatives.
Tax Legal Research and Analysis: Conduct legal research and analysis on various issues impacting the company, including analysis of new state tax laws, statutes, proposed, temporary and final regulations, state tax bulletins and other applicable guidance. Communicate findings in a clear and concise manner to internal stakeholders and upper management.
Legislative Advocacy: Partner with Verizon's state tax legislative affairs team to drive Verizon's tax legislative advocacy, including lobbying strategies, drafting comment letters, meeting with Government officials and lawmakers, participating in meetings with outside coalitions and drafting changes to proposed state tax legislation.
Mergers and Acquisitions: Provide expert tax advice on mergers, acquisitions, and restructuring, ensuring compliance with tax law and regulations, performing due diligence to assess and quantify tax risks, and working with internal teams to resolve and mitigate such risks.
State Tax Controversy: Assist in defending the company in state tax controversy matters; including developing strategies to deal with issues at state tax exams, state tax appeals, state tax tribunal boards and beyond, including collaborating with Verizon's state income and transaction tax audit teams, state tax litigation counsel and outside counsel.
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