Anonymous User wrote: ↑Sat Jan 21, 2023 1:05 pm
nealric wrote: ↑Sat Jan 21, 2023 12:46 pm
Anonymous User wrote: ↑Sat Jan 21, 2023 11:46 am
AllAboutTheBasis wrote: ↑Sat Jan 21, 2023 12:13 am
I had this exact thought the other day. For the other commenters, how does the actual day-to-day work in house compare to firms? Are you still doing tax research and writing?
A big part of it is that you absolutely have to pick up tax accounting. An in-house tax person can't function without being quite good at tax accounting and, in a very significant number of situations, in-house tax people were accountants first rather than lawyers. It involves significant retooling.
You'll have to be the one running models more often.
At a larger place, a HUGE amount of the focus is going to be on transfer pricing and dealing with cross-border issues, far more than in a normal firm where most of that is handled by the accounting people.
A lot of time spent on state tax issues, compliance with sales tax, use tax, etc., most of which is never dealt with much at a biglaw firm.
It all really boils down to the fact that at a firm, in most cases, you're focused on the tax implications of M&A deals. You're not doing the tax diligence for those deals, you're not focused on compliance work, etc. Totally different for an in-house person. It's a totally different thing. Many many many very good firm tax lawyers simply do not have any of the necessary toolkit to do it.
(I say this as a tax partner at a biglaw firm. There is zero chance I could move inhouse unless I agreed to start at the very lowest rung and totally retool. I explored it as a mid-level/senior, talked to the in-house folks at my clients about it, etc.)
There’s some truth to this, but I think you overstate a bit. I’ve been in-house tax for 10 years now. I don’t run models, but I will help accountants put them together. I’ve certainly picked up some tax accounting, but I wouldn’t be qualified to fill a tax accounting role.
A lot depends on the company and industry. Larger companies can afford more pure tax counsel roles that don’t overlap as much with the accounting side of the tax function. Megacorps can afford pure M&A tax counsel roles or pure transfer pricing counsel, etc. Some industries have different issues that are more/less important. For example, there’s very little transfer pricing work at my company due to the nature of the business (everything is tangible and we are on a very straightforward cost plus method). On the other hand, I some pure international work (I.e. work with foreign country tax laws) that I never did in biglaw.
Quoted anon. Fair enough. Certainly very true that every shop is different! Everything I said was based on my conversations with in-house tax folks at a variety of places, but obviously got some it wrong compared to your position (and I'm sure others).
Midlevel tax associate at a V20.
I think it depends on the role and whether you go to a F500 company, PE, hedge fund, sovereign wealth fund, asset manager, a bulge bracket bank, venture capital, alternative investment shop, etc.
I think the partner anon above is mostly referring to generic tax counsel folks in the F500 context. For instance, if you go to GM or some mega pharma like Pfizer or something, this is probably spot-on.
Nealric is at an oil company (or at least I think he is based on past postings) so his experience is also probably a bit more unique than your experience at a typical F500.
When I see my clients, the roles of tax counsels are vastly different.
When I talk to asset management company tax counsels focused on fund formations, they are doing a ton of research and analysis that go into cross-border tax structuring work, e.g., doing a deep-dive into tax treaties and implications under the Code on similar (e.g., are beneficial owners of non-US reverse hybrids eligible for treaty benefits?), thinking through 704c implications (e.g., is stuffing allocation valid?), 357c implications, etc etc. They then comment on our work on tax memos (marketing materials), term sheets, side letters, PPMs, LPAs, etc. Of course we do the heavy lifting, but they are involved in each step of the process. They seem to have access to Checkpoint, BNA, etc.
When I work with M&A tax counsels in PE shops, they work with us on considering each step of the M&A lifecycle, from LOI, tax structuring, diligence (farmed out to the big4 but we rely on them), bid stage to each step of the purchase agreement negotiations, etc.
Neither of the roles above seem to do modeling as they have accountants who do that side of the work.
Hedge fund tax counsel jobs seem to do some level of fund formation work akin to those in PE shops, but at the end of the day you are trading securities worldwide and unless you are working at Renaissance or something with some novel issues (basket options, etc), your typical day probably involves trying to understand a lot of non-US issues, e.g., Indian transfer taxes.
Bulge bracket banks are a mix of everything above, but boy they are stingy.
All this to say there are ample exit opportunities. Comp seems to vary a lot. Some clients work almost just as much as we do.
Recently I’ve been seeing some interesting job opportunities now with salary disclosures thanks to the new NY law, and saw a PE fund hiring with a 400-500k base plus bonus AND carried interest. I was tempted to apply but I want to make partner at my current firm. Also other PE / asset management jobs seem to be hiring midlevels at 300-350k base + bonus, which is a welcome change. A lot of other jobs seem to be mostly in the mid-200s to high-200s range base.
I know one person who was clearing 7 figures at a hedge fund as a tax counsel, just to add a datapoint. But that’s probably an exception to the norm.