Tax Talk

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georgej
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Tax Talk

Post by georgej » Mon Feb 05, 2018 3:38 pm

Tax avoidance, not evasion, in this practice area discussion thread.

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DOT
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Re: Tax Talk

Post by DOT » Tue Feb 06, 2018 5:14 pm

Subbing

Jimmy
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Re: Tax Talk

Post by Jimmy » Tue Feb 06, 2018 8:33 pm

I love tax. I wish I could practice it, but there aren't many opportunities in my market.

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heythatslife
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Re: Tax Talk

Post by heythatslife » Tue Feb 06, 2018 8:40 pm

I believe the correct term is "achieving tax efficiency"

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georgej
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Re: Tax Talk

Post by georgej » Wed Feb 07, 2018 8:28 am

heythatslife wrote:
Tue Feb 06, 2018 8:40 pm
I believe the correct term is "achieving tax efficiency"
Love that term!

What kind of junior tax tasks does everyone do? I have been updating a lot of private placement memoranda lately due to tax reform. I kind of like it as its a low pressure, high hours job and the basic skill of reading through something closely seems to translate well to other things.

Empty Chair
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Re: Tax Talk

Post by Empty Chair » Wed Feb 07, 2018 10:56 pm

First year tax associate at a non-NYC major market biglaw firm. Everyone in the group is insanely busy, and I’m not getting any work whatsoever (i.e., billing a couple hours a day at most for the past month to minor ongoing matters i’ve had for a couple months).

Anything to be concerned about, or am i just too junior to get staffed on tax matters when things are super hot? I’ve been thinking the latter but just want to make sure I’m not giving myself some sort of false sense of security.

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georgej
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Re: Tax Talk

Post by georgej » Thu Feb 08, 2018 7:34 am

Empty Chair wrote:
Wed Feb 07, 2018 10:56 pm
First year tax associate at a non-NYC major market biglaw firm. Everyone in the group is insanely busy, and I’m not getting any work whatsoever (i.e., billing a couple hours a day at most for the past month to minor ongoing matters i’ve had for a couple months).

Anything to be concerned about, or am i just too junior to get staffed on tax matters when things are super hot? I’ve been thinking the latter but just want to make sure I’m not giving myself some sort of false sense of security.
It's tough to say. Are there any other tax first years in your class, and are they busy? Is the firm pretty rigid about what clients you are staffed on or can you pretty much hit anyone up for work?

Empty Chair
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Re: Tax Talk

Post by Empty Chair » Thu Feb 08, 2018 8:19 am

georgej wrote:
Thu Feb 08, 2018 7:34 am
Empty Chair wrote:
Wed Feb 07, 2018 10:56 pm
First year tax associate at a non-NYC major market biglaw firm. Everyone in the group is insanely busy, and I’m not getting any work whatsoever (i.e., billing a couple hours a day at most for the past month to minor ongoing matters i’ve had for a couple months).

Anything to be concerned about, or am i just too junior to get staffed on tax matters when things are super hot? I’ve been thinking the latter but just want to make sure I’m not giving myself some sort of false sense of security.
It's tough to say. Are there any other tax first years in your class, and are they busy? Is the firm pretty rigid about what clients you are staffed on or can you pretty much hit anyone up for work?
Only first year tax associate. I can basically go to anyone I want to for work (and have been). It’s also an unwritten rule that first years don’t have an hours requirement of any sort, so I’m not immediately worried about my job, just trying to figure out if I should start thinking about switching practice areas or firms for longevity purposes.

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DOT
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Re: Tax Talk

Post by DOT » Mon Mar 19, 2018 10:00 am

Hey do you guys go to any local / [your city] networking events regularly? I'm wondering if I should be mingling with more tax people on a semi-regular/occasional basis.

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presh
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Re: Tax Talk

Post by presh » Thu Apr 05, 2018 4:10 pm

georgej wrote:
Mon Feb 05, 2018 3:38 pm
Tax avoidance, not evasion, in this practice area discussion thread.
Just here to keep y’all honest. 😉

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soj
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Re: Tax Talk

Post by soj » Thu Apr 05, 2018 5:00 pm

never use the f-word (fraud) or the sh-word (shelter). if you do, you ahve to say "economic substance" three times to absolve yourself.

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presh
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Re: Tax Talk

Post by presh » Thu Apr 05, 2018 5:18 pm

soj wrote:
Thu Apr 05, 2018 5:00 pm
never use the f-word (fraud) or the sh-word (shelter). if you do, you ahve to say "economic substance" three times to absolve yourself.
Don’t do it in front of a mirror or you’ll summon an IRS agent.

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ggocat
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Re: Tax Talk

Post by ggocat » Thu Apr 05, 2018 5:24 pm

Man, I was a paralegal on a tax shelter refund case in the mid-aughts. I thought a bunch of those people should have gone to prison, yet all they had to do was pay a penalty (for their own taxes) that was way less than the fees they collected for selling the shelter.

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MKC
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Re: Tax Talk

Post by MKC » Thu Apr 05, 2018 5:34 pm

ggocat wrote:
Thu Apr 05, 2018 5:24 pm
Man, I was a paralegal on a tax shelter refund case in the mid-aughts. I thought a bunch of those people should have gone to prison, yet all they had to do was pay a penalty (for their own taxes) that was way less than the fees they collected for selling the shelter.
My grandfather got caught up in one of these in the eighties and the IRS fined him something like $60,000, and he was not a rich man. He did hate taxes though, and was willing to listen to an accountant that told him it was legal to set up a sham charity to funnel money to his kids as a tax deduction.

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ggocat
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Re: Tax Talk

Post by ggocat » Thu Apr 05, 2018 5:46 pm

Yeah I have empathy for the actual taxpayers, just not the law firms, accounting firms, and hedge fund managers who marketed the shelters. If I as a taxpayer have an accountant or law firm telling me everything is peachy, I'd expect as such. So not criminal for the taxpayer... Still, from the taxpayer perspective, reminds me of the saying "if something sounds too good to be true..."

NourishAndStrengthen
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Re: Tax Talk

Post by NourishAndStrengthen » Tue Apr 17, 2018 1:56 am

Really interested in working in tax. Would someone care to answer a few questions:

1. What percent of your work is substantive vs. doc review?
2. What do you like about the practice?
3. What don’t you like about the practice?
4. How much of your work is deal work and how much is consulting/advisory work?
5. I’ve heard that tax groups’ hours tend to be more regular, how true is this? What are your hours like?

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proteinshake
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Re: Tax Talk

Post by proteinshake » Tue Apr 17, 2018 11:23 am

NourishAndStrengthen wrote:
Tue Apr 17, 2018 1:56 am
Really interested in working in tax. Would someone care to answer a few questions:

1. What percent of your work is substantive vs. doc review?
2. What do you like about the practice?
3. What don’t you like about the practice?
4. How much of your work is deal work and how much is consulting/advisory work?
5. I’ve heard that tax groups’ hours tend to be more regular, how true is this? What are your hours like?
also interested!

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DOT
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Re: Tax Talk

Post by DOT » Wed Apr 18, 2018 4:50 pm

DOT wrote:
Mon Mar 19, 2018 10:00 am
Hey do you guys go to any local / [your city] networking events regularly? I'm wondering if I should be mingling with more tax people on a semi-regular/occasional basis.
So i'm going to some big tax networking event next month

Maybe i'll worm my way into a fancy new job

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georgej
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Re: Tax Talk

Post by georgej » Fri Apr 20, 2018 9:12 am

NourishAndStrengthen wrote:
Tue Apr 17, 2018 1:56 am
Really interested in working in tax. Would someone care to answer a few questions:

1. What percent of your work is substantive vs. doc review?
2. What do you like about the practice?
3. What don’t you like about the practice?
4. How much of your work is deal work and how much is consulting/advisory work?
5. I’ve heard that tax groups’ hours tend to be more regular, how true is this? What are your hours like?
Fantastic questions, NourishAndStrengthen. I think like any practice area, the answers to these questions can vary a lot based on what partners you work with and what kind of corporate department you are supporting. In my experience, however:

1. I would say probably 33% of my work is substantive as a junior tax associate, which might not sound great but I think is a lot higher than corporate juniors. I don't really do doc review (which I think of as a litigation thing), but I do read a lot of the same form contract over and over again to make sure that a handful of tax topics are adequately addressed. The 33% I am counting as substantive includes stuff like drafting new provisions, research, and communications with other lawyers. The other stuff isn't always terrible and borders on substantive whenever its something I haven't really seen before.

2. I like that the tax law changes a lot, which leads to a lot of internal debate and discussion. There's also an interesting dynamic working with opposing counsel because both sides can win if less money gets funneled away in taxes, so its more collaborative sometimes than you might expect.

3. I think in tax you never get a great sense of an entire deal because you look at so many and just work on the same piece over and over. Corporate lawyers are more intimately involved in the whole thing, which I could see being cool.

4. I pretty much only do transactional work, but some of the transactions I work on have much longer timelines than M&A so there is a fair bit of consulting. All this entails, really though, is doing some research for a partner and sitting on a phone call while they do the advising.

5. I think the hours are a bit more regular, but not by a ton. Extrapolating from the beginning of the year, I expect I'll bill about 2100 hours by the end of this year.

NourishAndStrengthen
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Re: Tax Talk

Post by NourishAndStrengthen » Sun Apr 22, 2018 12:03 pm

georgej wrote:
Fri Apr 20, 2018 9:12 am
NourishAndStrengthen wrote:
Tue Apr 17, 2018 1:56 am
Really interested in working in tax. Would someone care to answer a few questions:

1. What percent of your work is substantive vs. doc review?
2. What do you like about the practice?
3. What don’t you like about the practice?
4. How much of your work is deal work and how much is consulting/advisory work?
5. I’ve heard that tax groups’ hours tend to be more regular, how true is this? What are your hours like?
Fantastic questions, NourishAndStrengthen. I think like any practice area, the answers to these questions can vary a lot based on what partners you work with and what kind of corporate department you are supporting. In my experience, however:

1. I would say probably 33% of my work is substantive as a junior tax associate, which might not sound great but I think is a lot higher than corporate juniors. I don't really do doc review (which I think of as a litigation thing), but I do read a lot of the same form contract over and over again to make sure that a handful of tax topics are adequately addressed. The 33% I am counting as substantive includes stuff like drafting new provisions, research, and communications with other lawyers. The other stuff isn't always terrible and borders on substantive whenever its something I haven't really seen before.

2. I like that the tax law changes a lot, which leads to a lot of internal debate and discussion. There's also an interesting dynamic working with opposing counsel because both sides can win if less money gets funneled away in taxes, so its more collaborative sometimes than you might expect.

3. I think in tax you never get a great sense of an entire deal because you look at so many and just work on the same piece over and over. Corporate lawyers are more intimately involved in the whole thing, which I could see being cool.

4. I pretty much only do transactional work, but some of the transactions I work on have much longer timelines than M&A so there is a fair bit of consulting. All this entails, really though, is doing some research for a partner and sitting on a phone call while they do the advising.

5. I think the hours are a bit more regular, but not by a ton. Extrapolating from the beginning of the year, I expect I'll bill about 2100 hours by the end of this year.
Thanks, this was really helpful and interesting.

In regards to the first one, I guess I meant substantive work vs. due diligence type work. It sounds like 1/3 of your time is doing substantive stuff and the other 2/3 is spent redlining and doing due diligence?

For hours, I guess I was asking about consistency and work flow. To use an exaggerated example, from some personal experience (friends/relatives), it seems that if an M&A lawyer works 50 hours/week then he spends 3 days doing nothing, 2 days working 20 hours and 1 day working 10. For tax is it more 9 hours for 5 days, and 5 hours for 1 day?

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georgej
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Re: Tax Talk

Post by georgej » Tue May 01, 2018 7:46 pm

NourishAndStrengthen wrote:
Sun Apr 22, 2018 12:03 pm
georgej wrote:
Fri Apr 20, 2018 9:12 am
NourishAndStrengthen wrote:
Tue Apr 17, 2018 1:56 am
Really interested in working in tax. Would someone care to answer a few questions:

1. What percent of your work is substantive vs. doc review?
2. What do you like about the practice?
3. What don’t you like about the practice?
4. How much of your work is deal work and how much is consulting/advisory work?
5. I’ve heard that tax groups’ hours tend to be more regular, how true is this? What are your hours like?
Fantastic questions, NourishAndStrengthen. I think like any practice area, the answers to these questions can vary a lot based on what partners you work with and what kind of corporate department you are supporting. In my experience, however:

1. I would say probably 33% of my work is substantive as a junior tax associate, which might not sound great but I think is a lot higher than corporate juniors. I don't really do doc review (which I think of as a litigation thing), but I do read a lot of the same form contract over and over again to make sure that a handful of tax topics are adequately addressed. The 33% I am counting as substantive includes stuff like drafting new provisions, research, and communications with other lawyers. The other stuff isn't always terrible and borders on substantive whenever its something I haven't really seen before.

2. I like that the tax law changes a lot, which leads to a lot of internal debate and discussion. There's also an interesting dynamic working with opposing counsel because both sides can win if less money gets funneled away in taxes, so its more collaborative sometimes than you might expect.

3. I think in tax you never get a great sense of an entire deal because you look at so many and just work on the same piece over and over. Corporate lawyers are more intimately involved in the whole thing, which I could see being cool.

4. I pretty much only do transactional work, but some of the transactions I work on have much longer timelines than M&A so there is a fair bit of consulting. All this entails, really though, is doing some research for a partner and sitting on a phone call while they do the advising.

5. I think the hours are a bit more regular, but not by a ton. Extrapolating from the beginning of the year, I expect I'll bill about 2100 hours by the end of this year.
Thanks, this was really helpful and interesting.

In regards to the first one, I guess I meant substantive work vs. due diligence type work. It sounds like 1/3 of your time is doing substantive stuff and the other 2/3 is spent redlining and doing due diligence?

For hours, I guess I was asking about consistency and work flow. To use an exaggerated example, from some personal experience (friends/relatives), it seems that if an M&A lawyer works 50 hours/week then he spends 3 days doing nothing, 2 days working 20 hours and 1 day working 10. For tax is it more 9 hours for 5 days, and 5 hours for 1 day?
Ah I see what you mean (i think you were clear before too but I am bad at reading). Generally, yes, the work flow is more consistent, but there can definitely be bad stretches where you work as much as a corporate lawyer.

WhereIsYonder
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Re: Tax Talk

Post by WhereIsYonder » Mon Nov 05, 2018 8:41 am

Does anyone here know when a big law tax associate could consider switching over to in-house (as in, what year does that move become a possibility)? Is there such a thing as leaving too early?

Stirfry
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Re: Tax Talk

Post by Stirfry » Sat Nov 17, 2018 7:19 pm

Has anyone here thought about the future of the profession.... mainly the future of tax groups inside law firms vs Big Four? Inhouse tax seems like a great option, but if someone wants to stay at a firm, what can they expect?

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Sinoper
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Re: Tax Talk

Post by Sinoper » Sat Nov 17, 2018 8:32 pm

Stirfry wrote:
Sat Nov 17, 2018 7:19 pm
Has anyone here thought about the future of the profession.... mainly the future of tax groups inside law firms vs Big Four? Inhouse tax seems like a great option, but if someone wants to stay at a firm, what can they expect?
I'd like to point out that it's more than a binary of in house or firm/big4. There are some really great government opportunities, namely DOJ Tax, IRS OCC, Treasury's Office of Tax Policy (includes sub-offices of Benefits Tax Counsel, International Tax Counsel, Tax Analysis, and Tax Legislative Counsel), Senate Finance Committee, House Ways and Means Committee, and Joint Committee on Taxation. Of course, you take a pretty mean pay cut (even more so than in house), but you're still in the $120k-$180k bracket for what it's worth.

I know I didn't answer your question, but I thought I should at least expand the scope of opportunities for consideration.

Stirfry
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Re: Tax Talk

Post by Stirfry » Sun Nov 18, 2018 12:06 am

Sinoper wrote:
Sat Nov 17, 2018 8:32 pm
Stirfry wrote:
Sat Nov 17, 2018 7:19 pm
Has anyone here thought about the future of the profession.... mainly the future of tax groups inside law firms vs Big Four? Inhouse tax seems like a great option, but if someone wants to stay at a firm, what can they expect?
I'd like to point out that it's more than a binary of in house or firm/big4. There are some really great government opportunities, namely DOJ Tax, IRS OCC, Treasury's Office of Tax Policy (includes sub-offices of Benefits Tax Counsel, International Tax Counsel, Tax Analysis, and Tax Legislative Counsel), Senate Finance Committee, House Ways and Means Committee, and Joint Committee on Taxation. Of course, you take a pretty mean pay cut (even more so than in house), but you're still in the $120k-$180k bracket for what it's worth.

I know I didn't answer your question, but I thought I should at least expand the scope of opportunities for consideration.
All of those positions are in DC though....

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