Develop individually customized transactional risk strategies to protect participants from tax opinion risks arrising in connection with business mergers and acquisitions in collaboration with Tax Opinion Insurance Underwriters, Business Owners, Public Company C-Level Executives and Senior Tax Professionals.

Highly visible position with global insurance company with incredible compensation package for short work week designed for a parent. Work with top legal and finance minds and the business community bringing together entities for greater efficiencies. Fortune 500 benefits package, executive perquisites, expense account and world class compensation package.

Position involves many facets of wergers and acquisitions tax issues such as:

*** Definitions related to ordinary and capital gain such as: Inventory, depreciated assets, and ordinary income assets; and Non-ordinary assets such as cash basis accounts receivable, depreciation recapture, etc.

*** Buyer and seller allocation of purchase price as, for example, an asset or 338 transaction; IRC Section 1060; GAAP treatment related to structuring and purchase price allocation; Section 1231 gains such as: goodwill, land, and other assets with fair market values higher than original tax cost; Section 197 issues such as: short-lived assets including machinery and equipment, inventory, prepaid expenses, etc.

*** Sales and Other Transfer Taxes.

*** Determining which transaction costs are related to and deductable for reportable capital gains or ordinary income.

*** Post-Transaction Filing Elections and Requirement such as: Adjusting or selecting different tax elections and accounting periods and methods; Year-end conformity with affiliated companies' year-ends and "short-period" returns; Responsibility for the pre- and post-acquisition income tax, payroll tax, property tax and other filings.

*** S Corp Targets and Section 338(h)(10) election in order to step-up the acquired assets.

*** Accrued Liabilities & Contingent Expenses such as: Pre-acquisition liabilities assumed buyers; Tax deductibility of post-acquisition payments; Unrecorded liabilities; Unrecorded assets including tax refunds associated with loss carryback potential and unclaimed tax credits and assets not shown in the balance sheet.

*** Tax basis asset revaluation using IRC Section 338(g), 338(h)(10), or Section 754 election and step-up and loss benefits on selected assets.

*** Financing structuring issues involving: Cash, notes, stock and affects on tax-free reorganizations: Foreign debt financing; multiple State complexities; IRC Section 163(j) interest stripping rules; and debt recharacterization.

*** Tax attribute carryovers and related conditions such as: High tax basis in operating assets, Net operating loss, Tax credits; Annual utilization of losses, deferrment and caps.

*** Analyzing proposed, ongoing and completed transactions for tax risks and tax benefits:

*** Advising on tax-efficient restructurings.

*** Interpreting complex legislative and regulatory actions relating to corporate and partnership transactions.

*** Performing financial analysis to assess the tax consequences of specific transactions.

For complete details contact Greg Foss at:
(609) 584-9000 ext 270

Or submit resume online at:
http://dmc9.com/gbf/app.asp

Or email to:
1000026345_10006796@jobbank302.com

Please reference #37126374 when responding.

5+ years

New York

$200,000.00

$250,000.00

Greg Foss

(609) 584 9000 ext 270

1000026345_10006796@jobbank302.com

http://dmc9.com/gbf/app.asp

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