Manager, WNT- Tax Controversy & Dispute Resolution Services

At KPMG, you can become an integral part of a dynamic team at one of the world's top tax firms. Enjoy a collaborative, future-forward culture that empowers your success. Work with KPMG's extensive network of specialists; enjoy access to our Ignition Centers, where deep industry knowledge merges with cutting-edge technologies to create innovative tax solutions. Join a diverse team helping high-profile clients understand, analyze, and respond to complex business opportunities and challenges. Develop your career through a range of multifaceted engagements, formal training, and informal mentoring. At KPMG, we believe nothing is more important than investing in our culture because it's an investment in our people, our future, and what we stand for as a firm.

• Represent clients at various levels of their IRS controversy from pre-examination (including Pre-Filing Agreements and ruling requests), through examination, appeals and into post-appeal mediation
• Operate with a general involvement and management of IRS audits, including responding to information document requests, notices of proposed adjustments and other exam related matters
• Prepare protests to thirty-day letters and represent clients before the IRS Independent Office of Appeals
• Assist with Competent Authority submissions
• Aid with voluntary disclosures to the IRS to correct compliance errors involving missed filings, withholding tax errors and other similar issues
• Review penalty abatement request letters and assist in the execution of penalty abatement services in federal penalty cases

• Minimum five years of recent tax experience performing tax research, representing clients in federal controversies, and providing technical advice on tax issues; government attorneys require experience in representing the government position in federal tax matters
• Bachelor's degree from an accredited college or university; Licensed CPA, EA or JD/LLM, in addition to others on KPMG's approved credential listing; should you like to see the complete list of currently approved designations/credentials for the hiring practice/service line, your recruiter can provide you with that list
• Specific knowledge of transfer pricing issues and resolution processes including competent authority proceedings and APAs preferred
• Experience working for or dealing with the government in the tax controversy matters, focused on LB&I cases, or controversy experience in another public accounting firm, law firm and/or corporate controversy experience, similarly focused on the LB&I examination process and related issues
• Strong understanding of the operations of the IRS, its procedures, and its processes
• Excellent communication, public speaking, research and writing skills with the ability to articulate complex tax issues and positions

KPMG LLP (the U.S. member firm of KPMG International) offers a comprehensive compensation and benefits package. KPMG is an affirmative action-equal opportunity employer. KPMG complies with all applicable federal, state and local laws regarding recruitment and hiring. All qualified applicants are considered for employment without regard to race, color, religion, age, sex, sexual orientation, gender identity, national origin, citizenship status, disability, protected veteran status, or any other category protected by applicable federal, state or local laws. The attached link contains further information regarding the firm's compliance with federal, state and local recruitment and hiring laws. No phone calls or agencies please.

KPMG does not currently require partners or employees to be fully vaccinated or test negative for COVID-19 in order to go to KPMG offices, client sites or KPMG events, except when mandated by federal, state or local law. In some circumstances, clients also may require proof of vaccination or testing (e.g., to go to the client site).

KPMG recruits on a rolling basis. Candidates are considered as they apply, until the opportunity is filled. Candidates are encouraged to apply expeditiously to any role(s) for which they are qualified that is also of interest to them.

Los Angeles County applicants: Material job duties for this position are listed above. Criminal history may have a direct, adverse, and negative relationship with some of the material job duties of this position. These include the duties and responsibilities listed above, as well as the abilities to adhere to company policies, exercise sound judgment, effectively manage stress and work safely and respectfully with others, exhibit trustworthiness, and safeguard business operations and company reputation. Pursuant to the California Fair Chance Act, Los Angeles County Fair Chance Ordinance for Employers, Fair Chance Initiative for Hiring Ordinance, and San Francisco Fair Chance Ordinance, we will consider for employment qualified applicants with arrest and conviction records.