Description:
Position Specific Description:Members of the Federal Tax Planning & Policy team (1) serve as the U.S. federal tax subject matter experts for the organization, being responsible for formulating and defending A Wholesale Electricity Supplier Company's federal tax positions with respect to all major transactions, investments, financings, and joint ventures; and (2) work with internal stakeholders and industry groups to drive the company's federal tax legislative agenda.
- Serve as internal U.S. federal tax counsel on all material federal tax issues
- Help identify and vet tax minimizing positions, and ensure that these positions are consistent, supportable, and documented
- Ensure tax quality control by researching and drafting memos and other necessary documents for all material tax positions that are audit-ready and entitled to applicable protections (e.g., attorney-client privilege)
- ssues involve (1) Subchapter K, Subchapter C, and consolidated return regulations; (2) tax equity and other financing transactions; (3) qualification for renewables tax credits; and (4) tax methods
- Analyze and communicate to senior management and other internal stakeholders the impact of all relevant proposed or final federal tax legislation/guidance
- Partner with internal stakeholders (including the company's Government Affairs group in D.C.) and industry groups to help draft and advocate for legislation/guidance beneficial to A Wholesale Electricity Supplier Company
- Provide counsel regarding tax risk management, including trackable/uncertain tax positions and FIN 48 determinations
- Help develop tax technical knowledge within the tax group by promoting knowledge-sharing and consistency and providing real-time updates on emerging tax technical issues and changes in law/regulations
Job Overview:
Employees in this job drive value by providing support to the organization with respect to the tax aspects of pending acquisitions, dispositions, financings, reorganizations, restructurings, and joint ventures, with a view to optimize taxes.
Job Duties & Responsibilities:
- Serve as the US federal income tax single point of accountability for assigned projects and identify state income tax and non-income tax issues
- Support various worldwide tax projects, including analyzing relevant tax law for tax planning transactions; working with foreign and domestic tax advisors to understand relevant tax rules; partnering with multiple business units to understand both domestic and foreign tax implications; and preparing and/or reviewing financial models to illustrate the tax consequences of various alternatives
- Communicate complex technical tax issues to management and internal stakeholders
- Draft and review tax provisions
- Prepare technical tax memoranda
- Performs other job-related duties as assigned
Required Qualifications:
- Bachelor's Degree
- Juris Doctorate
- Experience: 3+ years
- Member in Good Standing of State Bar
Preferred Qualifications:
LLM - Master of Laws