Tax Attorney

• Lead sophisticated individual income tax planning for high-net-worth individuals, business owners, investors, and family principals.
• Structure and advise on pass-through entity strategies, including Subchapter K and S planning, basis management, and entity selection for closely held businesses.
• Draft and execute the transactional documentation that implements the plan, including entity formations, operating agreements, assignments of LLC and partnership interests, deed transfers, promissory notes, and related instruments.
• Integrate estate planning considerations into the income tax plan, coordinating with trust and estate counsel or handling select trust work where it supports the client relationship.
• Advise on real estate tax planning, including section 1031 exchanges, section 721 transactions, and related structures.
• Guide clients through California residency planning and multi-state exposure for individuals and their closely held interests.
• Prepare technical memoranda and planning recommendations grounded in current statutory, regulatory, and administrative guidance.
• Conduct substantive tax research as the complexity of each matter requires, leveraging modern research platforms and AI-assisted tools.
• Provide occasional support on tax controversy matters for individual clients, including audit responses and IRS and FTB notice resolution. This is a limited portion of the role.

• Serve as the lead tax attorney on high-net-worth individual and family client relationships, delivering proactive, year-round service.
• Design and implement income tax strategies across investment portfolios, closely held business interests, and real estate holdings.
• Identify and execute planning opportunities through return review, quarterly projections, and ongoing client dialogue.
• Collaborate with internal CPAs and external advisors, including wealth managers and investment bankers, to deliver coordinated solutions.
• Lead client meetings with confidence, technical authority, and commercial judgment.

• Prepare assignments of LLC and partnership interests for gifting, sales, and internal restructurings.
• Handle deed transfers, including grant deeds, trust transfer deeds, and related real estate documentation tied to the planning.
• Coordinate filings, recording, and funding steps so every structure is implemented cleanly, not just designed on paper.
• Form and restructure closely held entities, including LLCs, partnerships, and S corporations, to support the client’s tax plan.
• Draft and review operating agreements, partnership agreements, and related governance documents, along with amendments as client structures evolve.

• Bring estate planning fluency to integrated client conversations, including trust structures, lifetime gifting, and wealth transfer considerations.
• Coordinate with estate planning counsel on implementation, funding, and ongoing administration where it supports the client’s tax plan.
• Advise on the income tax consequences of trust structures, including fiduciary income tax and distribution planning.

• Conduct well-reasoned tax research to support sophisticated planning, recognizing that complex individual matters routinely require deep technical work.
• Produce clear, authoritative technical memoranda and planning recommendations.
• Stay current on federal and California tax legislative, regulatory, and case law developments and communicate the impact to clients and colleagues.
• Use AI-assisted research platforms such as Bloomberg, Checkpoint, and Blue J with sound professional judgment.

• Serve as a go-to resource for colleagues on individual tax questions, particularly for high-net-worth client matters.
• Partner with business tax, compliance, and accounting teams on integrated client engagements.
• Contribute to internal training sessions, knowledge-sharing, and firm improvement initiatives.

• Develop and maintain a personalized Balanced Scorecard (BSC) that outlines your strategic steps toward personal and professional growth in alignment with firm goals.
• Provide guidance and on-the-job training to junior attorneys and support staff.
• Participate actively in firm initiatives and team activities.
• Maintain required CPE and CLE.

• 5 to 7 years of experience in high-net-worth individual tax planning at a law firm, CPA firm private client group, or integrated advisory practice.
• Deep technical command of individual income tax planning, including pass-through entities, closely held business interests, liquidity events, and real estate holdings.
• California residency and multi-state income tax planning experience.
• Hands-on experience drafting and implementing transactional documentation, including entity formations, operating and partnership agreements, assignments of LLC and partnership interests, deed transfers, and promissory notes.
• Estate planning experience, including trust structures, lifetime gifting, and wealth transfer concepts, sufficient to support integrated planning conversations.
• Strong tax research skills and the ability to produce clear, well-reasoned written analysis on complex matters.
• Comfort with AI-assisted legal and tax research tools.
• Outstanding written and verbal communication skills, including the ability to explain complex tax issues to non-attorney clients.
• JD and LLM in Taxation required. Active California Bar membership required.

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