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SALT Controversy & Advisory Architect | Junior Associate

§ Practice Area: Multistate Tax Litigation / Strategic SALT Planning & Consulting

§ Location: New York, NY

§ Salary: $225,000 to $260,000 Base Salary (Aligned with AmLaw 100 standards; inclusive of premium bonus eligibility and benefits)

§ Schedule: Full-time, Direct-Hire, Minimum 1,850 hours annual billed

The Firm Our client is a globally integrated AmLaw 100 firm, currently holding the #58 spot on the Vault Law 100 and recognized as a "Most Feared" litigation powerhouse by BTI Consulting for five consecutive years. The State & Local Tax (SALT) practice group is a cornerstone of the firm’s regulatory excellence, boasting a National Tier 1 ranking in Tax Litigation and Tax Law. The team is uniquely comprised of former state revenue officials and high-level tax policymakers, providing an insider’s perspective that few competitors can match.

Operating from the firm's New York hub, this practice serves over 20% of the Fortune 50, navigating the most complex fiscal challenges across all 50 U.S. jurisdictions. The New York team is specifically celebrated for its "out-of-the-box" thinking in high-stakes controversy and its ability to handle "billion-dollar questions" involving nexus, apportionment, and emerging digital products taxes. Candidates will join a culture that has been named the "Most Innovative Law Firm in North America" by the Financial Times, offering a rare blend of traditional prestige and forward-thinking legal technology.

§ Duties:

The SALT Controversy & Advisory Architect will function as a vital legal strategist for industry-leading corporations, focusing on the mitigation of tax liabilities and the resolution of complex multistate disputes. This role is highly collaborative, offering direct involvement in landmark cases that shape state tax jurisprudence.

Core responsibilities include:

⨖ Architecting comprehensive legal research and drafting sophisticated protests, pleadings, and appellate briefs for high-stakes SALT controversies.

⨖ Supporting senior counsel in all phases of multistate tax audits, administrative appeals, and judicial litigation before state tax authorities and tribunals.

⨖ Collaborating on the design of tax-efficient corporate structures and providing strategic advice on the SALT implications of transformative M&A transactions.

⨖ Engaging in settlement negotiations with state revenue agencies to resolve complex income, franchise, and sales/use tax disputes.

⨖ Monitoring and analyzing legislative developments to provide proactive policy advocacy and strategic planning for Fortune 100 clients.

⨖ Managing the development of practice-wide trainings and technical presentations on emerging tax trends, such as digital advertising gross receipts taxes and remote workforce nexus.

§ Qualifications:

⨖ Juris Doctor (J.D.) from an ABA-accredited law school with a distinguished academic record.

⨖ Active Bar Membership in the State of New York in good standing.

⨖ One (1) to Three (3) Years of substantive experience in state and local tax law or general tax controversy.

⨖ Exceptional drafting and analytical skills, with a proven ability to synthesize complex statutory frameworks into persuasive legal arguments.

⨖ Demonstrated initiative and a commitment to professional growth within a specialized, high-stakes practice group.

§ Skills:

⨖ An L.L.M. in Taxation from a premier academic institution is highly preferred.

⨖ Prior experience at an AmLaw 100 firm or a Big 4 accounting firm’s SALT practice.

⨖ Particular expertise or a genuine interest in the tax treatment of intangibles, digital products, or e-commerce transactions.

⨖ Strong oral communication skills suitable for high-level client interactions and participation in administrative hearings.

⨖ Exposure to multistate apportionment issues and the application of the Cape Town Convention or similar jurisdictional tax treaties is a plus.

!Notice¡ *

This a job advertisement on behalf of our client and does not reflect the full job description for the role. Any qualified candidates are encouraged to apply. You will need to provide law school transcripts, a writing sample or deal sheets, and a cover letter in order to be considered for this role. This posting does not constitute an offer of employment. and the listed compensation details may vary by state or experience and will be discussed thoroughly during interview phase.