Transactional tax lawyer-research & writing Forum

[Anonymous User]

How much time does a transactional tax lawyer in biglaw or big4 spend on research and writing memos? I am admitted to the NYU Tax LLM and want to do tax law because I enjoyed the puzzle solving nature of the tax class. I love figuring out complex corporate transaction diagrams, but am really uncomfortable with legal research & writing in general. (it often overwhelms and confuses me and made me anxious)

Does the amount of research and writing depend on law firm vs. accounting firm or practice area (m&a vs. international)? Or will I do tons of research and writing no matter which area or where you practice. Thanks!!

[Anon2468]

You can generally avoid writing long memos/opinion letters in big4 if that’s not your thing (assuming you’re not in WNT).

However, you’re obviously expected to know your way around the code and regs to understand the rules.

[zchen5]

You can generally avoid writing long memos/opinion letters in big4 if that’s not your thing (assuming you’re not in WNT).

However, you’re obviously expected to know your way around the code and regs to understand the rules.

Op here. Thanks for responding! So what does tax attorney in big4 do on a daily basis in a field office? I really enjoy the tax class in law school where you are asked to apply the code to complex fact patterns and transactions. I also enjoy the number crunching. Would that actual practice in big4 look somewhat similar or requires similar skills?

[hangtime813]

You can generally avoid writing long memos/opinion letters in big4 if that’s not your thing (assuming you’re not in WNT).

However, you’re obviously expected to know your way around the code and regs to understand the rules.

Op here. Thanks for responding! So what does tax attorney in big4 do on a daily basis in a field office? I really enjoy the tax class in law school where you are asked to apply the code to complex fact patterns and transactions. I also enjoy the number crunching. Would that actual practice in big4 look somewhat similar or requires similar skills?

Some JDs at Big4 get stuck doing compliance work like the rest of the other CPAs/non JDs which some people absolutely hated. Others do controversy or planning work which did involve a good amount of research and building decks and the such.

[lawschooled321]

You'll start with a lot of diligence work in the Big 4, but even as you move up the ranks you won't draft as many memos, etc. as you would if you worked in Big Law tax.

[notinbiglaw]

How much time does a transactional tax lawyer in biglaw or big4 spend on research and writing memos? I am admitted to the NYU Tax LLM and want to do tax law because I enjoyed the puzzle solving nature of the tax class. I love figuring out complex corporate transaction diagrams, but am really uncomfortable with legal research & writing in general. (it often overwhelms and confuses me and made me anxious)

Does the amount of research and writing depend on law firm vs. accounting firm or practice area (m&a vs. international)? Or will I do tons of research and writing no matter which area or where you practice. Thanks!!

I wrote a bunch of stuff but the TLDR is you don't need to do much research & writing even in BigLaw tax if you don't want to and you can almost entirely avoid it at Big 4 if you wanted to. But if you want puzzle solving, you need to seriously consider dealing with the limited writing at BigLaw because most of B4 "consulting" (outside of M&A) is standardized/routine deals that have basically the same analysis over and over.

[nealric]

How much time does a transactional tax lawyer in biglaw or big4 spend on research and writing memos? I am admitted to the NYU Tax LLM and want to do tax law because I enjoyed the puzzle solving nature of the tax class. I love figuring out complex corporate transaction diagrams, but am really uncomfortable with legal research & writing in general. (it often overwhelms and confuses me and made me anxious)

Does the amount of research and writing depend on law firm vs. accounting firm or practice area (m&a vs. international)? Or will I do tons of research and writing no matter which area or where you practice. Thanks!!

I wrote a bunch of stuff but the TLDR is you don't need to do much research & writing even in BigLaw tax if you don't want to and you can almost entirely avoid it at Big 4 if you wanted to. But if you want puzzle solving, you need to seriously consider dealing with the limited writing at BigLaw because most of B4 "consulting" (outside of M&A) is standardized/routine deals that have basically the same analysis over and over.

That wasn't my experience at all. Research and writing was at least half of what I did in biglaw (other half was diligence and deal doc markup). You can puzzle solve all you want, but that the end of the day, you have to be able to put your solution down in writing. Even if you could figure out a way to avoid writing, it would be to your disadvantage to do so. The amount of writing will go down as you get more senior (partners don't do much beyond a few paragraphs), but you have to be able to do it as as junior.

OP, if writing makes you nervous, I'd first try to work on it. Legal writing is nothing like creative writing, so you shouldn't have to worry about not coming up with ideas. Ideally, you've "solved the puzzle" before you've sat down to write. If you haven't solved the puzzle, then your problem isn't the writing. There's a format to be followed, and an inherent structure that flows from how the Code relates to the issue you are examining.

[Tefinn]

I agree with the other comments that attorneys in Big4 can avoid legal writing to a very large degree. Feel free to PM me if you’re curious about the career path. I’m in an M&A group at a Big4.

[Anonymous User]

Anon cause dont wanna out the anecdotal sources below.

I was at a big4 and am in biglaw tax now, and I’d say while from a generalized perspective it’s true you wouldn’t do as much writing in the big4 as in biglaw, this will all depend on the group/partners you work for in either of the places. If you are in a big4 field office in a group with 5 partners that are all academic, you may well end up doing 80%+ research/writing for them (this was the case for one of my friends). If you are in biglaw thats diligence heavy, even as a tax associate you may end up doing much more of that than research & writing (again anecdotal but one of my friends rarely did research/writing when he/she was at biglaw cause the firm had hundreds of tax associates and that friend kinda got away with it by being the deal tax person, i.e., constantly marking up agreements).

But OP, like nealric said above, writing is the key component to being a good tax lawyer. Wherever you are, if you aren’t able to effectively communicate the complex concepts in tax to non-tax folks, you may not get very far, so it’s critical to polish that skill over time. No one’s good on day one, but as you get trained you’ll gradually get better.

[Anonymous User]

I work in biglaw at a firm whose tax group does primarily international work, though also some deal work.

The associates that focus on tax planning -- whether international tax planning or domestic tax planning, like corporate reorganizations -- spend the vast majority of their time writing complex tax opinions, with those opinions generally focusing on the code, the regulations, any relevant IRS guidance (i.e., Rev Rulings, Rev Procs, PLRs, etc) and any relevant court cases (both within and outside the Tax Court).

The associates that focus on deal work (at least at my firm) do not draft any tax opinions and therefore spend far, far fewer time doing activities like the above. They'll still occasionally need to research and write up support for a certain tax position, but it's more infrequent and typically more informal (i.e., in an email support to a tax partner, or in a very boiled down fashion to a corporate partner). Instead, they'll spend most of their time marking up different deal documents and ensuring it's up to speed with what we want from a tax perspective, making sure all necessary tax elections are filed and communicated, doing basic tax due diligence, etc.

[jagpaw]

What firms are known for planning work? And difference in pace of work/lifestyle and exit options vs. deal work?

[Anonymous User]

I agree with the other comments that attorneys in Big4 can avoid legal writing to a very large degree. Feel free to PM me if you’re curious about the career path. I’m in an M&A group at a Big4.

OP here. Thanks for all of your reply!!! I tried to PM you but my PM is disabled.. . Can you tell me a little bit more of what exactly junior LLMs do in M&A big four? What are the specific tasks junior will be doing? What will a junior associate do in "tax due diligence" or "compliance work"? And what is building "the deck"?

Thanks!!!!!

[CanadianWolf]

If you want to minimize legal writing duties, consider focusing on Section 382 work for M&A in Big 4.

Also, if a writing sample is requested when interviewing, then....