Tax Attorney

Detroit office of our client seeks a tax attorney with 3+ years of experience. The ideal candidate should have experience in transactional tax law experience. The candidate should understand the parties tax objectives in a transaction, can identify the issues that typically arise affecting those objectives and propose solutions; can draft moderately complex operating agreements, and tax provisions in other transactional documents and ancillary tax documents. Must be knowledgeable with recurring transactional tax concepts (such as basis step-up, gain characterization, personal goodwill, profits interests, F reorganizations and 338(h)(10) elections, purchase price allocations, Section 754 elections vs. Section 704(c) allocations, debt-financing of distributions, qualified small business stock (1202), tax-free corporate contributions and reorganizations and issues on LLC formation (disguised sales, 99-5)). Should have significant experience using RIA/CCH, BNA, and TaxNotes (and other resources) to research tax issues thoroughly.