Corporate Tax Attorney Forum

[Maserati91]

I've been researching into this field and it seems very interesting. I know that in law school, you should use your elective credits in tax law classes but do you think a CPA is necessary?

Say you get an undergrad degree in finance, go to a t-14 law school, and then seek a job as a corporate tax attorney at biglaw, would it be okay to not have a cpa? Thanks for the input.

Also, do tax attorneys follow the same route to partner as regular corporate attorneys? Is it more competitive? What are exit options?

[Maserati91]

anyone... anyone at all?

[bk1]

anyone... anyone at all?

It's only been a couple hours.

[Curry]

This is purely anecdotal but from my understanding, tax attorneys rarely have CPAs. They take tax classes and work for a firm which sometimes sends them to get an LLM in Tax.

[ahduth]

I don't think you generally prepare tax returns as a tax attorney, so it's not necessary to be a CPA. I imagine you need to be able to understand the accounting, but no one needs a CPA to be able to do that. Accounting tends to be kind of obvious.

[thesealocust]

Tax attorneys at most large law firms neither require at entry level nor possesses as a group accounting credentials or background. Their specialty is in interpretation and analysis of the more complex parts of the code rather than adding up dollars and cents.

The only special training tax attorneys sometimes get are LLMs, and even there it's common for firms to send associates to get the LLM after hiring them rather than hiring students who have received them directly.

[PriOSky]

.

[thesealocust]

What do corporate tax lawyers do exactly? Do they structure tax shields?

Some specialize in "tax controversy" which is a polite way of saying "picking fights with the IRS." (Well, more like defending tax payers the IRS has already picked a fight with, but still). A large portion work on structuring transactions. The code is huge and complicated, and the precise methods you use to effectuate an economic goal (transferring property, merging two corporate entities, establishing a foreign joint venture) will have a dramatic effect on what - if any - tax consequences exist. This is actually often the most important part of a deal, an the tax department will be the major force in deciding the precise structure of a transaction. Still others work on areas of the tax code that essentially create markets: Things like ERISA, executive compensation, 401(k) funds (pro tip: 401(k) is a section of the internal revenue code), and insurance products. The federal income tax consequences to each individual investor will be small potatoes, but the precise way the products are structured to millions of people generates hefty legal fees. Real estate transactions generate complicated tax treatment, etc.

Big firm lawyers tend to be involved in areas where complex structures or heavy interpretation of the code, regulations, IRS publications, and case law are important.

[Renzo]

Tax lawyers try desperately to help companies avoid this:

Sony said Monday that the projection of a $3.2 billion net loss for the fiscal year ended March 2011 was largely due to writing off $4.4 billion related to a tax credit booked in a previous quarter.

[ahduth]

Tax lawyers try desperately to help companies avoid this:

Sony said Monday that the projection of a $3.2 billion net loss for the fiscal year ended March 2011 was largely due to writing off $4.4 billion related to a tax credit booked in a previous quarter.

I'd guess that's actually on the tax accountants. Booking a tax credit like that is something companies do when there is some sort of differential between the realization and the payment of a tax penalty/benefit. It's possible the accountants got bad advice from the tax strategy people, but the specific treatment of tax liability within the financial statements is the province of the accounting folks.

[Renzo]

Tax lawyers try desperately to help companies avoid this:

Sony said Monday that the projection of a $3.2 billion net loss for the fiscal year ended March 2011 was largely due to writing off $4.4 billion related to a tax credit booked in a previous quarter.

I'd guess that's actually on the tax accountants. Booking a tax credit like that is something companies do when there is some sort of differential between the realization and the payment of a tax penalty/benefit. It's possible the accountants got bad advice from the tax strategy people, but the specific treatment of tax liability within the financial statements is the province of the accounting folks.

I was being facetious; although it is an example of the kind of thing tax attorneys do. They tell what you could buy or spend money on so as not to squander $4 billion dollars in tax advantage.

[Maserati91]

Tax lawyers try desperately to help companies avoid this:

Sony said Monday that the projection of a $3.2 billion net loss for the fiscal year ended March 2011 was largely due to writing off $4.4 billion related to a tax credit booked in a previous quarter.

I'd guess that's actually on the tax accountants. Booking a tax credit like that is something companies do when there is some sort of differential between the realization and the payment of a tax penalty/benefit. It's possible the accountants got bad advice from the tax strategy people, but the specific treatment of tax liability within the financial statements is the province of the accounting folks.

I was being facetious; although it is an example of the kind of thing tax attorneys do. They tell what you could buy or spend money on so as not to squander $4 billion dollars in tax advantage.

Do you think it would be harder to get a job in BigLaw as a tax attorney if you don't have a CPA and your competition does?

[YaSvoboden]

Do you think it would be harder to get a job in BigLaw as a tax attorney if you don't have a CPA and your competition does?

Not hard enough to justify the extra schooling and work experience needed to get a CPA. If you want to be a tax lawyer, train to be a tax lawyer.

[anstone1988]

Do you think it would be harder to get a job in BigLaw as a tax attorney if you don't have a CPA and your competition does?

Not hard enough to justify the extra schooling and work experience needed to get a CPA. If you want to be a tax lawyer, train to be a tax lawyer.

How do you train to be a tax lawyer? Do you take tax related classes in law school for JD? Or do you go for a LLM from NYU?

[YaSvoboden]

Do you think it would be harder to get a job in BigLaw as a tax attorney if you don't have a CPA and your competition does?

Not hard enough to justify the extra schooling and work experience needed to get a CPA. If you want to be a tax lawyer, train to be a tax lawyer.

How do you train to be a tax lawyer? Do you take tax related classes in law school for JD? Or do you go for a LLM from NYU?

I'm still working on that one, but your guesses seem to be a good place to start. It definitely isn't through taking audit and financial accounting courses and then working in public accounting for a year. A lot of Macc programs with a tax emphasis only have 4 tax classes anyway, though there are some MTax programs that have more.

[robotclubmember]

to add to the consensus here, a certified public accountant is responsible for the preparation and attestation of financial statements and tax filings. tax attorneys would do none of these things. anecdotally (disclaimer: 0L here), cpa helps in oci, but moreso because being a cpa means you have professional work experience, probably from a firm, not for the sake of the license itself. that said, experience working in a firm will help you at oci for any field of biglaw, regardless of the type of firm, to varying levels.

being a cpa may be more helpful if you want to go into trust and estate law, but mostly from an image perspective. your clients tend to be individuals or small groups who invest a lot of faith in a guy with CPA at the end of their name, and client relations are important when you're working with individuals. but estate and trust law isn't the best area to make a name for yourself if you want partner track, it's a lot harder since you won't be able to find many individual clients willing to pay the billing rate.

long story short, cpa helps sorta, but in all the cases where it helps, it's not because the knowledge is useful. the benefit is indirect.

[thesealocust]

At an enormous number of firms, you won't be hired as a tax attorney. You'll just get hired and can choose to practice tax if you'd like. A CPA is just not something you need to be competitive in the industry of 'tax lawyers' as a whole.

[Mickey Quicknumbers]

You get to be a tax attorney by getting a job at a firm that handles tax related business, and telling them you want to work in tax.
Most people who become as tax attorneys (which is almost as vague a title as litigation or transaction) won't have more than a high GPA from their law school. Some will go back and get LLMs to advance their career in tax. Some will find a job after they get an LLM (or during, if you get one through a job fair).

Being a CPA does not make you more qualified for tax law, if that's what you're asking. But funny enough, LLM's do get hired to work for the big4, so it can work the other way.

[Maserati91]

You get to be a tax attorney by getting a job at a firm that handles tax related business, and telling them you want to work in tax.
Most people who become as tax attorneys (which is almost as vague a title as litigation or transaction) won't have more than a high GPA from their law school. Some will go back and get LLMs to advance their career in tax. Some will find a job after they get an LLM (or during, if you get one through a job fair).

Being a CPA does not make you more qualified for tax law, if that's what you're asking. But funny enough, LLM's do get hired to work for the big4, so it can work the other way.

This pretty much cleared everything up, thankss

[josehill]

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