Job description

IST - Risk, Controvery & Litigation Senior Associate

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Job Category:   Tax
Line of Service:   Tax
Location(s):   NY-New York
Travel Requirements:   0-20%
Level:   Senior Associate
Job ID:   106399BR
PwC/LOS Overview
PwC is a network of firms committed to delivering quality in assurance, tax and advisory services.

We help resolve complex issues for our clients and identify opportunities. Learn more about us at

At PwC, we develop leaders at all levels. The distinctive leadership framework we call the PwC Professional ( provides our people with a road map to grow their skills and build their careers. Our approach to ongoing development shapes employees into leaders, no matter the role or job title.

Are you ready to build a career in a rapidly changing world? Developing as a PwC Professional means that you will be ready
- to create and capture opportunities to advance your career and fulfill your potential. To learn more, visit us at

The PwC network is a global market leader in tax services.

We assist businesses, individuals, and organizations with tax strategy, planning, and compliance, while also delivering a wide range of business advisory services.

With over 32,000 tax professionals, this means that the PwC network can support our clients both locally and globally.

We have experience working with an expansive and diverse client-base, which comprises all types of businesses-multinationals, local companies, privately-owned organizations, entrepreneurs, family businesses, trusts, partnerships, and private individuals.

Job Description
Insourced Solutions for Tax (IST) positions at PwC are at the forefront of the tax profession
- creating a distinctive new approach to providing tax managed services. IST delivers top talent, technology, and processes across our global network to provide an alternative tax function model that is fit for purpose today and into the future. Clients are seeing this as an innovative collaboration in response to a strategic evolution in the global market for tax managed services.

The Insourced Solutions for Tax (IST) Risk Management, Controversy Solutions, and Litigation Support team is a national network of tax professionals prepared to help clients successfully navigate IRS process and procedure to facilitate compliance, drive negotiations, issue resolution, and assist with strategic planning. The team combines the knowledge and extensive experience of professionals from major law and accounting firms, leading in-house tax departments, and all major IRS functions including examinations, appeals, international, and Chief Counsel.

Position/Program Requirements
Minimum Year(s) of Experience: 3

Minimum Degree Required: Bachelor's degree

Degree Preferred: Juris Doctorate (JD) or Master of Laws (LLM) degree

Certification(s) Preferred: CPA or Active Member of the Bar.

Knowledge Preferred:

Demonstrates thorough knowledge and/or a proven record of success in the following areas:

- Tax controversy and litigation, including tax procedure, technical tax arguments, substantiation requirements, responding to inquiries from the Internal Revenue Service, managing federal audits, and managing risk for large multinational corporations;
- Technical tax specialization with both domestic and international issues arising in the corporate context; and,
- Technical and legal research of complex tax issues, transaction structuring for tax issues, due diligence, strategy formulation, financial modeling and tax planning.

Skills Preferred:

Demonstrates thorough abilities and/or a proven record of success in the following areas:

- Demonstrating controversy and litigation skills and preparing responses to IRS information document requests;
- Researching tax law questions that arise in a complex international and diversified company and preparing memos regarding the same topics;
- Interacting with clients, other third-party advisors and vendors on significant litigation matters;
- Coordinating valuation work and substantiating key return positions

and building relationships within significant corporate organizations;
- Applying and interpreting the U.S. federal income tax law as it relates to Sub-Chapter C corporations, Sub-Chapter S corporations, partnerships, consolidated groups, tax efficient structuring and use of debt, the reorganization provisions of the Internal Revenue Code, technical writing, and reviewing of opinion letters and memoranda;
- Identifying and addressing significant client needs, actively participating in client discussions and meetings and liaising with client management;
- Communicating a broad range of Firm services;
- Demonstrating project management, including preparing concise, accurate documents, working with team members to drive solutions, and balancing the occurrence of unanticipated issues;
- Acting as a team leader by creating a positive environment by working with team members to satisfy client expectations and respecting the work-life quality of team members; and,
- Providing candid, meaningful feedback in a timely manner and keeping leadership informed of progress and issues.

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