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Are you an experienced advocate with an interest in resolving federal tax controversies? Would you like to assist in resolving federal tax controversies involving a vast array of taxpayers, from large C-corporations to passthrough entities and individuals? Do you enjoy legal research, in addition to oral and written advocacy on behalf of your clients with respect to complex tax issues? Do you have a passion for applying your knowledge of IRS practice and procedure to attaining the best outcomes for your clients? Are you curious about the IRS's new centralized partnership audit regime and how it might apply to passthrough taxpayers?

If you answered "Yes" to any of these questions, you should consider a career in Deloitte's National Federal Tax Services practice with a focus on Federal Tax Controversy!

Recruiting for this role is anticipated to go until 5/31/2025.

Work you'll do

As a Senior within Deloitte's National Tax Controversy Services practice, you will be part of an experienced team of professionals committed to resolving clients' federal tax controversies and providing clients with in-depth knowledge of IRS practice and procedure. Deloitte's Federal Tax Controversy professionals work to resolve a wide variety of issues with the IRS and are well-versed in achieving the best possible outcomes on behalf of Deloitte's clients. Many of our professionals have worked, for example, at the IRS and Treasury as executives, counsel, appeals officers, and revenue agents.

Responsibilities will include:

• Pre-examination audit readiness analysis

• Examination planning and representation

• IRS Appeals representation

• Drafting and negotiation of Private Letter Rulings and 9100 relief requests

• Drafting of tax opinions and memoranda

• Penalty abatement requests

• Litigation support

The Team

At Deloitte Tax LLP, our Federal Tax Controversy team provides dispute resolution services to clients with respect to all types of tax issues, including, for example, those involving transfer pricing, the section 41 research credit, and the section 48 investment tax credit. Our Federal Tax Controversy specialists serve clients ranging from Fortune 100 C-corporations to sophisticated private equity funds and individuals. Our team is committed to leveraging our research and advocacy expertise to achieve the best possible outcomes for our clients.

Qualifications

Required

• 3+ years of tax experience

• 1 to 2 years of federal tax experience

• Experience in corporate and partnership tax

• Bachelor's degree in Accounting, Finance, or other business-related field

• Ability to perform job responsibilities within a hybrid work model that requires US Tax professionals to co-locate in person 2-3 days per week.

• Previous law firm, IRS, Treasury, Big 4, or CPA firm experience

• Ability to travel 25%, on average, based on the work you do and the clients and industries/sectors you serve.

• One of the following active accreditations obtained, in process, or willing to obtain:

• Licensed CPA in state of practice/primary office if eligible to sit for the CPA

• If not CPA eligible, one of the other designations listed below based on role requirements and business approval:

• Licensed attorney

• Enrolled Agent

• Project Management Professional (PMP)

• Chartered Financial Advisor (CFA)

Preferred

• Advanced degree such as Masters of Tax, JD and/or LLM, Macc, or MBA

• Experience with respect to federal tax controversy issues, specifically

• Excellent research skills

• Excellent written and verbal communication skills

The wage range for this role takes into account the wide range of factors that are considered in making compensation decisions including but not limited to skill sets; experience and training; licensure and certifications; and other business and organizational needs. The disclosed range estimate has not been adjusted for the applicable geographic differential associated with the location at which the position may be filled. At Deloitte, it is not typical for an individual to be hired at or near the top of the range for their role and compensation decisions are dependent on the facts and circumstances of each case. A reasonable estimate of the current range is $66,570 to $151,580.

You may also be eligible to participate in a discretionary annual incentive program, subject to the rules governing the program, whereby an award, if any, depends on various factors, including, without limitation, individual and organizational performance.

Information for applicants with a need for accommodation: https://www2.deloitte.com/us/en/pages/careers/articles/join-deloitte-assistance-for-disabled-applicants.html

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All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability or protected veteran status, or any other legally protected basis, in accordance with applicable law.