Tax Director | Partnership​/LLC Pass - Entities - National Tax Office

Subject Matter Expert For Partnership/LLC Tax Practice

CBIZ's National Tax Office is in search of a Subject Matter Expert to join its Partnership/LLC tax practice. The ideal candidate will bring leading expertise as it relates to the complex world of partnership and LLC taxation. Given our rapid growth both organically and via acquisitions, we are in need of a high-level candidate, so that we can shape internal policy and maintain an acceptable level of responsiveness to our offices' consultation needs in this area.

Essential Functions and Primary Duties

• Provide tax consultation to tax professionals in our practice offices on a variety of client tax matters throughout our national footprint. A primary emphasis will involve the "700 series" of the Internal Revenue Code, with secondary involvement in other ubiquitous areas of federal taxation (e.g., sections 170, 453, 469, etc.) as needed.
• Lead the Partnership/LLC allocation modeling practice, which includes both "hands-on" involvement and management of others with respect to the creation or validation of waterfall and target allocations, capital account revaluations, and section 704(c) special allocations.
• Contribute to the Partnerships/LLC tax practice of the National Tax Office in projects that involve shaping and maintaining associated national policies and standards, providing timely insight on emerging technical matters, and identifying and implementing associated tax planning initiatives.
• Serve as a Subject Matter Expert for complex questions from our practice offices involving partnership pass-through taxation, such as mergers/acquisitions, equity-based compensation, profit/loss allocations (including waterfall and target capital allocations), profits interests, treatment of debt and quasi-debt instruments, impact of recourse vs. nonrecourse financing, debt work-outs, minimum gain allocations, tiered partnership issues, special basis adjustments and step-up allocations, hot assets, IRS audits, conflicts of interest among equity holders and the entity, partner/member/shareholder agreements, self-employment and limited partner determinations, private letter ruling requests, etc.
• Serve as a Subject Matter Expert for tax compliance reporting questions involving partnership pass-through taxation, such as evolving information disclosure requirements, amended return procedures, administrative adjustment requests, partnership representative matters, etc.
• In addition to providing client consultation in a variety of tax technical areas, we expect this person to contribute to the National Tax Office's thought leadership programs, training programs, and risk management initiatives. This includes ongoing familiarity with trending legislative, administrative, and judicial developments. This would supplement current resources performing in those areas. Flexibility to travel is important, as programs and meetings occur across the country.
• The candidate should have a vision on how to expand the NTO billable practice in the partnership/LLC tax area, with the goal of hiring more partnership/LLC subject matter experts into NTO to assist the leaders.
• The candidate should also have broad expertise across the gamut of domestic federal tax issues. Many of the inquiries from local offices involve complex or unusual issues that require the expertise of our group but cannot be limited to specific sections or areas of the Internal Revenue Code. All NTO team members are expected to help answer these inquiries in a way that provides the best client service experience.

Preferred Qualifications

• 8+ years of tax partnership experience with a top a top-tier law firm or accounting firm, or similar experience in academia
• Distinguished career in partnership pass-through taxation
• Bachelor's degree in accounting
• CPA, Masters in Taxation or JD/LLM
• Strong proficiency with tax research subscription services including Bloomberg Tax, Thomson Reuters Checkpoint, CCH Answer Connect, and Tax Analysts.
• Strong desire to be a part of and contribute to the growth of a high performing client focused team
• Have a consulting mindset and approach to client interaction and expectations. Recognize that we…