Tax Attorney

Talley LLP•Orange, CA

1d•Hybrid

About The Position

Talley Law Group is seeking a Tax Attorney to lead sophisticated individual tax planning for its high-net-worth clients. This role is designed for an attorney with expertise in complex individual income tax, structuring solutions for business owners, investors, and family principals, and experience in estate planning to facilitate integrated, multi-year planning conversations. The ideal candidate will possess a deep technical understanding of individual tax planning and the ability to manage matters involving pass-through entities, closely held business interests, liquidity events, real estate holdings, and California residency planning. While estate planning experience is beneficial, it is not the primary focus of this position.

Requirements

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.

Nice To Haves

Estate planning experience supports the work but is not the primary focus.

Responsibilities

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 transactional documentation for plan implementation, such as entity formations, operating agreements, assignments of LLC and partnership interests, deed transfers, promissory notes, and related instruments.
Integrate estate planning considerations into income tax plans, coordinating with trust and estate counsel or handling select trust work to support client relationships.
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 based on current statutory, regulatory, and administrative guidance.
Conduct substantive tax research using 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.