Tax Law Forum

[Xaintes]

The real question is: who the hell would enjoy tax law?

Since this very insightful question was not answered earlier, I shall elaborate: Nobody. People pretend that they "like" tax and tax law so as to convince people and themselves that they will not be doing the most mind numbing work known to man as a sellout for job stability and a decent paycheck.

What high paying job isn't a sellout? President of the United States? Supreme Court Justice? Astronaut?

ASTRONAUT!

[General Tso]

can the resident tax experts speak to the job market for Tax LLMs? my reading of taxtalent.com that there is almost zero hiring of Tax LLMs who failed to make the biglaw cut. seems strange that one could have WORSE job prospects than with a JD alone, especially given how dull and challenging tax law is.

[BeautifulSW]

Tax law and tax accounting are closely related, but distinct, professions. I personally enjoy tax law questions very much but I think I'd run screaming from having to actually prepare a Form 1120 and reconcile it to the General Ledger. To do corporate or large partnership planning and compliance you really need more accounting background (or supervision I suppose) than most lawyers start out with. OTOH, some CPA firms offer their commercial clients compliance and representation services through examination and maybe collections but will not tackle administrative appeals. Most are not licensed to go into Tax Court.

One of the recurring bits of advice the mentors on TaxTalent offer is that, ouside of BigLaw, a budding tax practitioner should seek the CPA before worrying about earning an LL.M. BigLaw cares less than nothing about whether you are a CPA. Another bit is that the ideal is to get the tax law job then have your employer pay for the LL.M. A final bit is that LL.M. entry hiring is abysmal right now but should pick up in the foreseeable future. Take it for what it is worth.

Non BigLaw tax lawyers who are not accountants seem to congregate in estate planning but that's just my own observation. It's interesting work and I think it will be in demand for some time to come but it isn't the really heavy duty stuff NYU prepares you for such as M&A.

[270910]

can the resident tax experts speak to the job market for Tax LLMs? my reading of taxtalent.com that there is almost zero hiring of Tax LLMs who failed to make the biglaw cut. seems strange that one could have WORSE job prospects than with a JD alone, especially given how dull and challenging tax law is.

This is my read it on it (I am not a resident tax expert, but have more experience / knowledge / connections in that field than most of big law, so take it for what it's worth).

[bmwhype2]

Tax law and tax accounting are closely related, but distinct, professions. I personally enjoy tax law questions very much but I think I'd run screaming from having to actually prepare a Form 1120 and reconcile it to the General Ledger. To do corporate or large partnership planning and compliance you really need more accounting background (or supervision I suppose) than most lawyers start out with. OTOH, some CPA firms offer their commercial clients compliance and representation services through examination and maybe collections but will not tackle administrative appeals. Most are not licensed to go into Tax Court.

One of the recurring bits of advice the mentors on TaxTalent offer is that, ouside of BigLaw, a budding tax practitioner should seek the CPA before worrying about earning an LL.M. BigLaw cares less than nothing about whether you are a CPA. Another bit is that the ideal is to get the tax law job then have your employer pay for the LL.M. A final bit is that LL.M. entry hiring is abysmal right now but should pick up in the foreseeable future. Take it for what it is worth.

Non BigLaw tax lawyers who are not accountants seem to congregate in estate planning but that's just my own observation. It's interesting work and I think it will be in demand for some time to come but it isn't the really heavy duty stuff NYU prepares you for such as M&A.

i am also an avid reader of CareerCoach on TaxTalent. He says the ideal combination is CPA/JD(top14). However, that forum ironically leans towards BigLaw and usually says Big4 tax is the PlanB.

[nealric]

i am also an avid reader of CareerCoach on TaxTalent. He says the ideal combination is CPA/JD(top14). However, that forum ironically leans towards BigLaw and usually says Big4 tax is the PlanB.

Which is odd, because VERY few biglaw tax partners are CPAs. In fact, not a single tax lawyer at my firm is a CPA. For people who are CPAs who decided to go to law school, good for them- i'm sure it could be quite helpful for some. But I think it makes no sense at all for someone with no accounting background who is considering tax law to try to get a CPA- in most states it would be almost as onerous getting a JD/LLM because of the work experience requirement. Only about 10% of my LLM classmates have CPA's (several classes did straw polls at the beginning). Frankly, I don't feel like the CPA's have much of an edge with anything we are doing in class.

As for the job postings above, I think you are confusing true tax counsel positions for tax manager positions. They can be quite different in what they are looking for. To be sure, many people looking to hire a tax manager would love to see a JD, but those are not JD required positions. If you want to be a tax manager, being a CPA is quite helpful.

[BeautifulSW]

I don't think it's so odd, really, though I get your point. The Tax Talent career coaches (there have been several over the years) freely admit that being a CPA won't help at all for getting a BigLaw tax associate position. It might even hurt, I guess, if someone thinks you aren't totally committed to being a tax lawyer. But the general idea is that tax practice is a much bigger field than just BigLaw and that being a CPA will open many more of those non-BigLaw doors than, say, an LL.M.

[nealric]

I don't think it's so odd, really, though I get your point. The Tax Talent career coaches (there have been several over the years) freely admit that being a CPA won't help at all for getting a BigLaw tax associate position. It might even hurt, I guess, if someone thinks you aren't totally committed to being a tax lawyer. But the general idea is that tax practice is a much bigger field than just BigLaw and that being a CPA will open many more of those non-BigLaw doors than, say, an LL.M.

I just mean it's odd in the sense that everyone in the forum seems to be gunning for biglaw or IRS, but the career coach doesn't really give tax advice centered around those types of positions.

[BeautifulSW]

Oh, I see. Yes, you're right about that. Tax Talent seems to be more of a talent-hunting company for corporations and accounting firms, maybe because I understand that BigLaw doesn't recruit new tax associates through headhunting organizations. Well, there is a decided attitude among some fraction of law students and wanna-bes (who post there and here) that anyone who isn't doing BigLaw is by definition a loser.

I certainly don't agree with that attitude but I have to admit that the ever-increasing cost of a J.D. makes seeking a six figure salary mandatory and the only likely place for most new grads to make that much is BigLaw so maybe these kids aren't so foolish after all. As long as they know what they are getting into, it isn't any of MY business.

I do advise any J.D. who has no accounting background and didn't take more than "baby tax" in law school to try an experiment before committing to earning (and paying for) an LL.M. Study for and pass the U.S. Treasury's Special Enrollment Exam. The resulting license is of absolutely no value as an employment credential and of little use to a licensed attorney but the process of studying will show once and for all whether the student is really interested enough in the field to drop a bunch of money into the LL.M. It's also a useful prep, I think, for actually undertaking an LL.M. program. At this level, tax is tax.

[nealric]

Oh, I see. Yes, you're right about that. Tax Talent seems to be more of a talent-hunting company for corporations and accounting firms, maybe because I understand that BigLaw doesn't recruit new tax associates through headhunting organizations. Well, there is a decided attitude among some fraction of law students and wanna-bes (who post there and here) that anyone who isn't doing BigLaw is by definition a loser.

I certainly don't agree with that attitude but I have to admit that the ever-increasing cost of a J.D. makes seeking a six figure salary mandatory and the only likely place for most new grads to make that much is BigLaw so maybe these kids aren't so foolish after all. As long as they know what they are getting into, it isn't any of MY business.

I do advise any J.D. who has no accounting background and didn't take more than "baby tax" in law school to try an experiment before committing to earning (and paying for) an LL.M. Study for and pass the U.S. Treasury's Special Enrollment Exam. The resulting license is of absolutely no value as an employment credential and of little use to a licensed attorney but the process of studying will show once and for all whether the student is really interested enough in the field to drop a bunch of money into the LL.M. It's also a useful prep, I think, for actually undertaking an LL.M. program. At this level, tax is tax.

I really don't see the point of studying for the Enrolled Agent exam. There is very little overlap between LLM classes and the content of the enrolled agent exam (especially if you are doing a planning focused course selection). I would certainly advise against enrolling in the LLM if all you took was Tax I in law school- mostly because your newfound tax interest will be a hard sell to employers and because you might not like the subject. If you are interested in the content of tax LLM classes, I suggest you look at the Corporate Taxation E&E and "The Logic of Subchapter K" (Partnership Tax handbook). It would also be a good idea to look through a few issues of some of the major tax publications (Tax Notes, Tax Law Review (NYU), Virginia Tax Review, The Tax Lawyer) to get an idea of what some of the big issues in tax law are right now.

[BeautifulSW]

Only because in the process of studying you will meet up with some pretty basic concepts such as adjusted basis, partnership allocations, and depreciation recapture. A J.D. with no tax background other than baby tax will likely never even have heard of these things.

In general, the SEE is a numbers exam and I agree not hugely germaine. It's accounting much more than law. BUt if even that much effort to understand fundamental tax concepts gives you hives, it might be an indicator that tax isn't the best fit. It's true that tax lawyers don't generally do numbers, that's what accountants are for, but it's easier to understand those accountants if you at least know what numbers look like. As I say, it's just a suggestion and doesn't entail much time or expense.

[Danteshek]

Hi. I appreciate the discussion here. I went to a panel today at Loyola on scholarly tax writing. Has anyone here written a publishable piece on a tax law topic? If so, how did you go about finding the topic?

[JakeL]

can the resident tax experts speak to the job market for Tax LLMs? my reading of taxtalent.com that there is almost zero hiring of Tax LLMs who failed to make the biglaw cut. seems strange that one could have WORSE job prospects than with a JD alone, especially given how dull and challenging tax law is.

Well, Chief Counsel is hiring like crazy, and will continue to be doing so for years.... If you are qualified, you will find a job.

[nealric]

Well, Chief Counsel is hiring like crazy, and will continue to be doing so for years.... If you are qualified, you will find a job.

I know plenty of well-qualified tax people who would amputate a limb to get on at chief counsel. It's not easy.

Hi. I appreciate the discussion here. I went to a panel today at Loyola on scholarly tax writing. Has anyone here written a publishable piece on a tax law topic? If so, how did you go about finding the topic?

I'm currently working on getting an article published (one bite so far). Until you know a decent bit of tax, it's going to be really hard to come up with a topic yourself. The best bet is to talk to tax professor or lawyer and talk to them about up and coming issues. It's also worth following tax dailys like the Tax Analysis and BNA Tax Daily for ideas (should be on Lexis).

[Danteshek]

Cool. I am currently writing a Note on Securities for my school's law review (btw BNA Securities Law daily is great! I didn't know there was one for tax). I'm planning to enter the SEC student writing competition (worked there last summer). I have an idea already for a follow up Note on a tax law topic that is related. If that goes well I might enter Tennenwald competition (sp?) as well. I interview with Chief Counsel about 10 days ago.

[taxguy]

I am a practicing tax lawyer for over 25 years. I thought I would I would share a few sundry thoughts in response to all these posts:

First, you don't need a CPA or have to have an accounting background. I know many top tax lawyers who don't have this type of background. HOWEVER, having an accounting background really does help a lot. It not only provides a good practical tax background but gives a good financial grounding that can be vital for tax lawyers that do deals. Having a CPA does help with getting tax law jobs.

Secondly, although I am NOT big on the rankings, the rankings of grad tax programs is more or less spot on.

Third, most tax lawyers that I know have a masters in law ( Tax).

Third, as for jobs, as long as you attend a top 20 law school for undergrad or a top 5 grad program for tax, you should be able to get a job.

Fourth: You don't need to go to NYU , or Georgetown. Miami is a very good tax program especially for estate planning topics. In fact, they are one of the only schools that offers both LLM in estate planning and tax.

Fifth: Don't discount the ability to work for national accounting firms. Yes, you won't do documents such as wills, trusts etc. However, they do a lot of tax planning and opinion memos and pay reasonably well. In fact, if you keep your job and open mind regarding jobs, you will have more opportunites in tax than with most other disciplines

[BeautifulSW]

The only additional thought I have about taxguy's excellent post is that I personally remain unconvinced that an LL.M. is really necessary to do estate planning.

Most tax programs offer two fundamental courses for estate planners that most law students probably wouldn't have already taken. These are a course on wealth transfer taxation, called something like "Taxation of Estates, Gifts and Trusts" and "Income Taxation of Estates and Trusts". If you really master that material, you will know most of the tax you need to do estate planning. Some International Tax might prove useful as well, I suppose.

Those courses are not accounting-heavy but you do need to be comfortable with numbers.

There's lots of other stuff you also need to know but I question whether a whole master's degree is worth the expense. Of course, that's up to the individual and this is just my own opinion.

[anyuta]

I <3 SPAMMING!

...that's why I got banned.

[Littlejenny]

http://grad-schools.usnews.rankingsandr ... ls/tax-law
isn't this ranking reliable i'm confusing in choosing a school, pls provide me the most reliable infomation...


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[nealric]

is this ranking reliable i'm confusing in choosing a school, pls provide me the most reliable infomation...

It is an it isn't.

It's true that the best Tax LLM programs are NYU, Georgetown, UF, and Northwestern (in that order). Usually JD's can take advantage of the tax LLM courses. However, if you are choosing a JD program, it does not make sense to choose a higher ranked school over a lower ranked school simply because the tax ranking is high. It might make sense for choosing between similarly ranked schools. For example, it might make sense to choose Georgetown over Cornell or NYU over Chicago. It would not make any sense to choose NYU over Harvard.

[bmwhype2]

How much do first year lawyer Associates make in M&A tax at the big4?

[nealric]

How much do first year lawyer Associates make in M&A tax at the big4?

Depends where. There is a big difference between the National Tax offices in DC and the branch offices. The National tax offices usually work on more cutting-edge legal issues. The branch offices are mostly working on return stuff.

National tax will start around 120k
Branch starts around 60k

There are random exceptions though.

[bmwhype2]

How much do first year lawyer Associates make in M&A tax at the big4?

Depends where. There is a big difference between the National Tax offices in DC and the branch offices. The National tax offices usually work on more cutting-edge legal issues. The branch offices are mostly working on return stuff.

National tax will start around 120k
Branch starts around 60k

There are random exceptions though.

Ok. I see why everyone over at TaxTalent is gunning for BigLaw rather than Big4.

What if the first year lawyer came in as a JD w/ an LLM in tax? or several years as a Senior Tax Associate?

[bmwhype2]

In NYC, first year Tax Staff at Big4 start at 60-62k, so it kind of boggles the mind that they would pay a lawyer the same amount to do the tax compliance / returns considering that the Tax Staff may not need a one-year Masters in Accounting/Tax if their state only has 120credit hour requirement to sit for the CPA.

[nealric]

In NYC, first year Tax Staff at Big4 start at 60-62k, so it kind of boggles the mind that they would pay a lawyer the same amount to do the tax compliance / returns considering that the Tax Staff may not need a one-year Masters in Accounting/Tax if their state only has 120credit hour requirement to sit for the CPA.

It is what it is. A lot of JD's complain that they don't really even use their degrees at the Big4 branch offices.

What if the first year lawyer came in as a JD w/ an LLM in tax? or several years as a Senior Tax Associate?

For Big4 branch, LLM doesn't matter- 60k. A NYU/GULC LLM would give you a shot at the national offices.

If the candidate has several years as a Senior Tax Associate, they would probably come in at a higher level (depending on how much experience).

LLM also won't advance you a class year in biglaw. You are still a 1st year if you went right out of law school.