Senior Manager, Tax Controversy - Service Center

The Team

Deloitte Tax LLP, Tax Controversy Services Group ("TCS") provides responsive, innovative, and practical resolution of matters before the Internal Revenue Service ("IRS"). Deloitte Tax Controversy professionals understand the complexity of IRS practice and procedure. Many of our professionals formerly worked for the IRS and as executives, counsel, appeals officers, revenue agents, and service center/campus examiners. As global tax authorities streamline their processes and demand more information from taxpayers in shorter timeframes, managing tax examinations grows more challenging each day. We are efficient, accurate, and consistent in the way we manage our client's global tax controversy processes and global transparency.

The TCS team utilizes their extensive range of skills, knowledge, and experience to assist clients with their IRS conflicts by supplementing and assisting IRS departments, legal counsel, and other tax practitioners. TCS tax professionals help clients manage all of their global and domestic interactions with the IRS.

What You'll Do

We believe that experience is invaluable in the above situations. Our IRS Account Analysis specialists all have former IRS experience. The group has an average of 20-plus years of experience in dealing with IRS tax controversy matters. Each has the skills and knowledge to help clients work with IRS personnel on processing, procedural, and account-related matters.

We understand how IRS systems work, the documents and facts needed to address specific tax issues, methods to present those issues, and ways to resolve each tax problem. These qualities are essential for addressing the many types of tax and account issues companies encounter today.

The candidate will advise in such areas as exam management, preparation of penalty abatement, appeals protests, and other tax research submissions. In addition, the candidate will research tax return and account processing issues to ascertain the best direction for the resolution of such matters. These actions could also include management of IRS accounts for payment application issues, misapplication of extension requests, amended returns, statute issues, Form 911, Application for Tax payer Assistance Order , and all Entity related matters.

Responsibilities will include:

• Use your IRS expertise to provide many tax controversy services to our clients
• Manage teams on client engagements that can help address the risks and costs of dealing with the IRS and explore more favorable and efficient issue resolution
• Help clients address complex and dynamic issues surrounding tax controversy on a global level
• Research and analyze a wide range of tax issues related to business and individual transactions and tax implications of financing techniques
• Work with local and foreign market clients
• Conduct pre-post penalty abatement issues and resolution determinations
• Conduct pre-examination audit readiness analysis
• Exam planning and representation
• Participate in appeals representation and litigation support
• Provide support for IRS service center matters
• Manage computations of IRS penalties and interest
• Supervise assignments by the professional accountants serving as Consultants, and Senior Consultants. Assist client and Deloitte engagement teams with recurring IRS matters
• Interaction with IRS Practitioner Priority Service Line
• Prepare written correspondence to IRS and on behalf of Deloitte engagement teams regarding account resolution
• Coordinate services with Deloitte offices globally
• Provide support for the individual and business tax return compliance process
• Use internal technology to update/maintain client records and prepare reports

• Bachelor's degree
• Minimum 10 years IRS tax controversy experience. Experience should include, at least 4 years of experience as a former IRS revenue agent, appeals officer, or Counsel attorney.
• Must be able to demonstrate the ability to research tax issues effectively, document case files, maintain inventory management, and have excellent organizational skills.
• Ability to travel 25%, on average, based on the work you do and the clients and industries/sectors you serve.
• One of the following accreditations obtained:
  • Licensed CPA in state of practice/primary office if eligible to sit for the CPA
  • If not CPA eligible:
    • Licensed attorney
    • Enrolled Agent
    • Other certification (upon approval)

• Knowledge of the IRS exam and appeals process
• Extensive knowledge of IRS Campus Operations a plus
• Ability to research and understand the IRS methods of account resolution, desk guides, and the Internal Revenue Manual ("IRM")
• Excellent written and verbal communication skills
• Strong interpersonal skills with a management/executive presence
• Strong analytical abilities and computer skills with knowledge of MS Excel
• Experience developing and motivating the engagement staff by providing them with leadership, counseling, and career guidance
• Experience maintaining and developing strong client-taxpayer relationships on various business tax consulting and compliance engagements
• Ability to balance multiple assignments and other responsibilities.
• Basic knowledge and use of Microsoft Outlook, Excel and Word
• Limited immigration sponsorship may be available