Managing Director, Transaction Advisory Services (M&A Tax) (New York)

Job Summary:Within the Special Projects Group in Transaction Advisory Services (the Managing Director is responsible for advising clients on U.S. federal income tax issues associated with mergers and acquisitions. The Managing Director in this role will be the primary client contact for technical tax work. Tax technical work may involve structuring and restructuring, consolidated return subsidiary share basis and earnings and profits analyses, Section 1202, and transaction cost analyses, with the primary focus of the role will be on Section 382 consultative projects, with the foregoing workstreams occurring in the context of Section 382 projects. In addition to serving in a lead client-facing role, it is expected the Managing Director will interface with professionals in the firm to help drive technological innovation with respect to Section 382 analyses. The responsibilities of this role will include working with BDO counterparts in India to increase capacity for Section 382 consulting, training the TAS team and overall tax practice as to Section 382 tax technical topics, and improving BDO’s deliverables, tools, and templates related to Section 382. This position will review work prepared by Associate, Senior Associate, Manager, Senior Manager, and Director professionals in the Transaction Advisory Services Group, and work with Principals on client optimization strategies. In addition, the Managing Director will be involved in the marketing, networking, and business development within an area of expertise and specialization and may be asked to provide written tax advice to clients.Job Duties:Tax SpecializationUnderstands the technical and practical issues and opportunities regarding the taxation of corporate mergers, acquisitions, and restructurings involving corporate entities, including (but not limited to):
Form and ramifications of various taxable asset and stock transactionsPurchase price allocation rulesSection 338(h)(10), Section 338(g), and Section 336(e) electionsApplication of Section 1202 to stock dispositionsNet operating loss and credit limitation rules (e.g., SRLY, Sections 382, 383, and 384);Consolidated return regulations related to basis and E&P adjustments;Tax considerations for subsidiaries joining or leaving a consolidated group, such as the circular basis adjustment rules, the unified loss rule, NOL allocation rules, excess loss accounts, deferred intercompany transactions, triggering events, excess loss accounts, etc.Nonrecognition transactions and general requirementsTransaction costs and rules related to deductibility and capitalizationServes as a primary technical resource for the technical practice areas described above for the Firm and its clients, including with respect to the broader tax practiceTax ConsultingReviews calculations of anticipated tax ramifications of an asset deal relative to a stock dealReads and comments on stock purchase agreements and asset purchase agreementsReviews and analyzes purchase price allocationsConducts and reviews transaction costs analysesProvides tax consulting services to the broader tax practice on tax issues and opportunities with respect to corporate mergers, acquisitions, restructurings, and tax attributesLeads Section 382 studies and works with the Special Projects Group Leader to drive BDO’s overall strategy with respect to Section 382Reviews step plans for legal entity rationalization/restructuring transactions, including pre-transaction restructurings, post-deal integration entity alignments, and other reorganizationsReviews opinions, memoranda, and conducts tax technical research and analysisReviews stock basis and E&P analyses for consolidated groupsReviews inside and outside basis analyses for C corporationsFrames projects and issues for effective delegation to directors, senior managers, managers, senior associates and associatesReviews structure decks for taxable and nonrecognition transactions between unrelated third partiesResearchIdentifies when research is needed, clearly and concisely frames issues to be researched, and clearly and concisely reports the analysisApplies most Firm and professional standards for preparation of WTA and tax returnsInvolves additional firm specialists, as appropriateStrategy DevelopmentIntroduces and develops new or improved ideas for clients, the Firm, or Firm personnel, e.g., by reducing taxes or expenses or providing non-tax benefitsReviews studies of tax implications and offers clients alternative courses of actionIdentifies and leverages lessons learned on prior projects, and offers input on how to improve processes and methodsOther duties as requiredSupervisory Responsibilities:Supervises associates, senior associates, managers, senior managers, and/or directors on all projectsReviews work prepared by associates, senior associates, managers, senior managers, and directors and provides review commentsTrains associates, senior associates, managers, senior managers, and directors on how to use all current software tools and to improve tax technical skillsActs as a Career Advisor to associates, senior associates, managers, senior managers, and directorsSchedules and manages workload of associates, senior associates, managers, senior managers, and directorsProvides verbal and written performance feedback to associates, senior associates, managers, senior managers, and directorsQualifications, Knowledge, Skills, and Abilities:Education:Bachelor’s degree, required; major in Accounting, Finance, Economics, or Statistics, preferredJuris Doctor (JD) or Master of Laws (LLM) with a focus on Tax, preferredMaster’s degree in Accounting or Tax, preferredExperience:Ten (10) or more years of prior relevant tax experience and/or public accounting, private industry accounting, or legal experience in three or more of the areas listed below, required:
Knowledge of Section 382, and experience in preparing, reviewing, and auditing Section 382 studiesKnowledge of the consolidated return regulations, specifically experience in preparing, reviewing, and auditing consolidated subsidiary share basis and earnings and profits analysesKnowledge of Section 1202 and experience preparing and reviewing Section 1202 analysesExperience in preparing, reviewing, and auditing deliverables related to transaction structuring, legal entity rationalization, and post-transaction structural integrationExperience in preparing, reviewing, and auditing transaction cost analysesExperience in drafting technical tax memorandums and opinions to support client positionsLicense/Certifications:CPA certification, Attorney (admitted to practice in a U.S. jurisdiction), Internal Revenue Service Enrolled Agent (“EA”), or the equivalent of one of these designations, requiredPossession of other professional degrees or certifications applicable to the role, preferredSoftware:Proficient with the Microsoft Office Suite, preferredExperience with tax research databases, including Checkpoint, Bloomberg, and CCH Intelliconnect, preferredLanguage:N/AOther Knowledge, Skills, & Abilities:Superior verbal and written communication skillsAbility to effectively delegate work as neededStrong analytical, research and critical thinking skills as well as decision-making skillsAbility to work well in a team environmentAbility to develop team of tax professionalsAbility to compose written tax adviceAbility to effectively develop and maintain client relationshipsExecutive presence and ability to act as primary client contact for preparation and presentation of issues and resolutions to clientDemonstrates a high level of integrityAbility to adapt quickly in uncertain or unstructured situationsExcellent communication skills, with the ability to give and receive criticism and feedback constructivelyAbility to simplify complex issues for client and non-tax professional understandingAbility to utilize and improve digital tools to reduce hours and optimize engagement efficiencyIntellectually curious, motivated to deliver work of the highest quality, and driven to expand knowledge of tax technical matters, BDO’s business, its clients, and the teamAbility to lead by example, demonstrating to less experienced professionals the importance of continual personal and professional growthIndividual salaries that are offered to a candidate are determined after consideration of numerous factors including but not limited to the candidate’s qualifications, experience, skills, and geography.National Range: $250,000 - $350,000
Maryland Range: $250,000 - $350,000
NYC/Long Island/Westchester Range: $250,000 - $350,000Join us at BDO, where you will find more than a career, you’ll find a place where your work is impactful, and you are valued for your individuality. We offer flexibility and opportunities for advancement. Our culture is centered around making meaningful connections, approaching interactions with curiosity, and being true to yourself, all while making a positive difference in the world. At BDO, our purpose of helping people thrive every day is at the heart of everything we do. Together, we are focused on delivering exceptional and sustainable outcomes and value for our people, our clients, and our communities. BDO is proud to be an ESOP company, reflecting a culture that puts people first, by sharing financially in our growth in value with our U.S. team. BDO professionals provide assurance, tax and advisory services for a diverse range of clients across the U.S. and in over 160 countries through our global organization.BDO is the first large accounting and advisory organization to implement an Employee Stock Ownership Plan (ESOP). A qualified retirement plan, the ESOP offers participants a stake in the firm’s success through beneficial ownership and a unique opportunity to enhance their financial well-being. The ESOP stands as a compelling addition to our comprehensive compensation and Total Rewards benefits* offerings. The annual allocation to the