Tax Controversy Associate

Private Client and Tax Division

As the largest private client firm in the world, Withers is dedicated to successful people, their businesses, and their charitable and philanthropic objectives. The firm has over 650 lawyers across 17 offices around the world, including offices throughout the East and West Coasts of the United States, Europe and Asia. The firm has acted for 25% of the US Forbes 400 List of Wealthiest Americans, 75% of the top 100 UK Sunday Times Rich List, 52% of the Singapore Forbes Rich List, 35% of the Hong Kong Forbes Rich List, and 35% of the Sunday Times Top Philanthropists. The Private Client and Tax Division's reputation as trusted advisor to successful people and businesses is second to none.

The focus of this role will be representing clients in federal and state tax controversies – essentially wealth preservation and safeguarding the assets of our clients.  While most often this will involve voluntary disclosure cases (such as streamlined foreign offshore filings and IRS Criminal Investigation Voluntary Disclosure Practice submissions) and audits, this role can span the full spectrum of Tax Controversy, including, but not limited to, appeals, fast track mediation, amnesty filings, tax court, US District Court, collections, and competent authority requests.

The Role

This role is based in our New Haven office.

• Demonstrable tax controversy experience, e.g., clerkship with Tax Court, prior work experience for or experience representing taxpayers before the Internal Revenue Service with a law or CPA firm (such as in audit, voluntary disclosure or collections matters), or government agency in a civil or criminal tax capacity;
• International tax and reporting experience a plus (ex. FBARs, PFICs, CFCs, trusts, CTA, CRS, FATCA);
• Experience reviewing federal and state income tax returns, including international informational reporting forms, as well as associated documentation, e.g., bank and investment account statements;
• Ability to distill and summarize pertinent information, interpret tax laws, and help resolve client's tax issues related to their individual, entity, trusts & estates, domestic and international tax matters;
• Advanced writing skills to produce advocacy pieces to governmental authorities, and communications to clients and colleagues;
• Able to effectively communicate verbally with colleagues, clients, and the IRS;
• Negotiation experience with the IRS, State, or other governmental personnel; and
• The role will also involve contributing to the team's profile and undertaking business development activities to establish, develop, and maintain long-term relationships; including, writing articles/posts, attending events/conferences and building networks with private wealth contacts/intermediaries including offshore and peer firms and counsel.

This list of duties and responsibilities is not exhaustive.  It is intended to describe the general content of, and requirements for the performance of this job, and as such, the role may also include the undertaking of additional tasks as required.

Key Skills and Experience

• Strong academic credentials (J.D. required; LL.M. is a plus);
• Between 3 – 6 years of experience practicing in a law firm's tax controversy/audit, tax, international, and/or Private Client group, or a CPA firm tax or international tax group with some audit/controversy involvement;
• Connecticut Bar membership required;
• Strong drafting, writing, research and communication skills;
• Strong verbal skills including high degree of comfort with both phone and video communications; and
• Exposure to both domestic and international tax experience.
• Compensation commensurate with experience ranging from $195,000 - $270,000

About Withers

Where global collaboration achieves exceptional results. 

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A law firm focused on people and collaboration. 

For the past 125 years, Withers has supported some of the world’s most remarkable people and organizations at defining moments in their lives. 

We are the only international law firm focused on successful individuals and private capital, working closely with founders, investors and family offices. We also advise governments, charities, global brands and start-ups of all shapes and sizes.  Many of our clients are shaping the future, and creating solutions to tackle many of the world’s problems. It makes for a fascinating and challenging practice.  Our role is to get to know each individual client, find out where they want to be, and help them to get there – whether they are building a business, buying a home or protecting and defending their interests. To meet their unique needs we are exceptionally collaborative, working together across teams and time zones.  And we are agile – focusing on strategy rather than rigid ideas and traditional hierarchy.  

Join us to be part of a team that is always looking to the future.  Where initiative, big ideas and bold moves are always encouraged.  Where you can truly be yourself. 

We are delighted to announce that we have been awarded Mansfield Certification Plus in relation to our recruitment and leadership progression efforts in the US and UK. This certification is an encouraging milestone as we continue to champion diversity within our organization and in the wider legal sector. 

For more information on Withers, please visit the following links: General Career Site, LinkedIn, About Us 

Equal Opportunities Employment Statement 

The firm is an Equal Employment Opportunity employer.  Equal employment opportunity has been and will continue to be a fundamental principle at the firm. Employment at the firm is based upon personal capabilities and qualifications without regard to race, color, gender, sex, age, religion, creed, national origin, ancestry, citizenship, marital status, sexual orientation, physical or mental disability, medical condition, military and veteran status, gender identity or expression, genetic information, or any other characteristic protected by federal, state, or local law.  The firm prohibits and will not tolerate any discrimination or harassment on the basis of any of these classifications or characteristics.

If you are interested in applying for employment and need special assistance or an accommodation to use our website to apply for a position, please contact the firm at (203) 789-1320 or email us.recruiting@withersworldwide.com with your request.  Determinations on requests for reasonable accommodation are made on a case-by-case basis.