Our client, a global energy company, is in need of a tax attorney to join the legal department.

The role of the tax function is to continually optimize the Company's tax position, provide assurance that all tax requirements are met everywhere they operate and to provide a strategic tax planning service for all Group and Business activities.

The purpose is to comply with all legal requirements in the taxing jurisdictions in which the Group operates in a way that will optimize the Group's tax position.

To achieve this, the Company has a strategy to seek maximum efficiency in compliance activities while performing an assurance role, maintain active relationships with the Businesses to ensure that there is a mutual understanding of their operations and associated tax issues, and to work proactively to seek beneficial change or avoid detrimental change in tax legislation.

Role: The attorney in this position will be engaged in (1) federal and international income tax research, analysis, and planning as well as federal tax controversy matters; and (2) various aspects of state income/franchise tax planning as well as selected state income/franchise tax matters arising from state audits, administrative appeals and litigation.

Strong oral and written communication skills, as well as a high proficiency in performing electronic tax research, are essential.

AccountabilitiesFederal/International: Attorney will work closely with other members of the Corporate & International Planning Group and other members of the Tax Department, as well as members of Treasury, Law and relevant Business Units in the provision of tax advice and the resolution of tax issues.


Perform tax research and analysis with respect to a wide range of sophisticated federal and international tax issues and prepare well reasoned and well written memoranda supporting his or her legal conclusions, including assessments of tax risk.


From time to time represent the Company effectively before the IRS Appeals Office division with respect to the Companys position on various federal and international issues, both in written protests and in face-to-face meetings with the Appeals office.

State
Provide state income/franchise tax legal support to all business units (exploration and production, refining and marketing business, alternative energy, and integrated supply and trading), as well as to the state income/franchise tax compliance group.

Specific responsibilities include: - Review merger and acquisition documents and identify/resolve related state income/franchise tax issues - Model state income tax impact of mergers and acquisitions and capital development and disposition - Regularly work with the state income/franchise tax compliance group and advise as to legal soundness of state income tax return positions - Prepare written communication explaining tax law changes and their likely impact on the Company - Respond to various inquiries from business units on such matters as the availability of state income tax credits, withholding requirements, and economic impact of state income taxes on defined projects
Review tax returns to identify state tax savings opportunities
Research state income tax planning opportunities, prepare related opinions and economic models, and lead multifunctional teams in the execution of planning opportunities
Participate in state income tax audits and appeals by assessing legal soundness of state positions, developing legal rebuttals thereto, and, where appropriate, assisting in the negotiation of tax settlements
Assist in providing litigation support to outside counsel
Monitoring state income/franchise tax legislation, regulations and judicial decisions in all fifty states and the District of Columbia, analyzing key bills, modeling state income/franchise tax cost impact, providing strategic support to Government Affairs with respect to key legislation, and advising businesses how best to react to law changes.

Qualifications

1. Strong oral and written communication skills.

2. High proficiency in performing electronic tax research.

3. Minimum 5 years (4 years with LLM.) experience, in the aggregate, in the practice of both federal tax law and the practice of state income/franchise tax law in a corporate tax department, accounting firm, and/or law firm, the latter with a strong emphasis on planning.

4. Law degree from accredited US law school.

5. Licensed to practice law. Please apply online at http://eResume.ProvidusGroup.com and reference job #5218.

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