One of the defining characteristics of the ABA Tax Section membership is the fascinating variety of our career paths. Each of us brings a different perspective to being a tax lawyer. Our unique backgrounds and experiences combine with the many possibilities within our profession to produce a profoundly interesting set of stories on how we each arrived where we are today, and where we want to go next. Many of these perspectives were captured in the book, Careers in Tax Law, a compilation of essays from more than seventy practitioners across our profession. This resource provided insight into our varied worlds—but as with any printed publication, it was a snapshot in time and limited in scope.
The evolution of the printed NewsQuarterly into the all-digital ABA Tax Times has made it possible to bring in additional content. As part of this process, we are launching Paths in Tax, a regular column that will feature career insights from different perspectives within our profession. Each issue of Tax Times will include a discussion with a different individual, highlighting their path, the challenges they have faced, and the solutions they have found to make their practice their own. Coupled with People in Tax, the interview column focused on the movers and shakers of our profession, we will seek to expand our perspective, to educate and entertain, and ultimately to deepen our collective appreciation for the practice of tax.
To kick off this process of exploration, let me start with updating my own story. My contribution to Careers in Tax Law focused on the power of “Showing Up”—the massive impact of the simple act of grabbing opportunities. In the intervening time, the power of Showing Up has truly been driven home. Each opportunity I’ve taken has multiplied into new opportunities, leading in different and unexpected directions.
One of the most interesting components of that journey was the chance to go in-house. After five years with Big Four accounting (itself a less than traditional path), one of my colleagues recruited me to join the headquarters tax planning group for a U.S.-based multinational. This was a chance I was open to, if not specifically seeking out, and I jumped at it.
I want to be clear at the outset that in-house roles are as varied as the professionals who fill them—no two are the same. The differences are sometimes fundamental gulfs rather than modest variations. This column will definitely explore others’ experiences in different in-house roles. As for mine, it presented a very different set of challenges compared to client practice. To be fair, in many ways it still was client practice, just for a closely related set of clients. The key difference came in the scope: my colleagues and I were stewards not just of technical analysis, but of the mechanics of execution, in a seriously hands-on way.
When I made the switch, part of my rationale was to see transactions through “soup to nuts” and that rationale was realized in spades. As an in-house professional, a significant part of my work consisted of (almost literally) digging out the facts, and another significant part was doing post-transaction documentation, clean-up, and follow-up. Whether it was pouring over detailed trial balances and working with local accounting teams to figure out how (mechanically) to extract individual journal entries from the accounting systems or deciding what short phrase best describes the myriad contents of an Iron Mountain file box, the in-house role was at least one part project administrator for every part tax technician.
This beginning-to-end lifecycle involvement often facilitated one of the great joys of in-house work. Provided you have built the right relationships, you get involved long before there is the proverbial “chalk outline on the floor.” Colleagues bring you in at the start, giving you the luxury of a seat at the table at a time when you can still impact the facts. The buyout of a strategic partner, rather than an exercise in cleaning up after an unexpected Rev. Rul. 99-6 transaction, becomes an opportunity to rework a holding structure. Panicked research on the short-term exceptions under the section 956 “Investment in U.S. Property” rules – or, if fate really has it in for you, a massive un-budgeted U.S. income inclusion – can be stopped before it ever gets started. Without billing rates—real or imagined—working against you, your “clients” aren’t discouraged from seeking your input. The end result, when things are going well, is an environment of collaboration producing substantially better results than would otherwise be possible. All of this, of course, is dependent on the “front-line” professionals knowing to call you.
It is this last point that catches many, myself included, somewhat flat-footed. Networking is every bit as critical in-house as in private practice. While it’s true that you no longer live by the billable hour (and that really is as nice as it sounds), your ability to be effective depends directly on your ability to stay informed. Staying informed often depends directly on your network. Unfortunately, the standby mechanisms of relationship-building—the business lunch, golf outings (if that’s your thing), peer introductions, the dreaded cold-call—feel even more artificial when used within the structure of a single organization. As a result, a key to success is being able to network organically, through leveraging the casual introduction, following up on chance meetings, and rigorously maintaining ever-longer chains of contact. Water-cooler chats or the off-topic follow-up email become vital components of professional success.
Here is where Showing Up comes to the rescue again. Separated from the standard tools of business development, the opportunities for natural, unforced interaction are critical. Those opportunities primarily occur not through ordinary work, but through raising your hand—that is, through agreeing to take on the cross-functional project, volunteering for roles that broaden your exposure to the organization, and jumping on every chance to meet new people. You have to build connections in a context where it isn’t necessarily obvious to others why you are building them, all so they remember to call you when you need them to. The ability to build in this way naturally is a rare skill, but thankfully one that responds well to practice and determined effort. That said, if networking isn’t your thing, it’s entirely possible that in-house wouldn’t be either.
The other opportunity often afforded in-house is the chance to explore. The corporate world offers a much greater variety of “hats” than any client practice. This is partly because corporations have many roles that simply aren’t replicated in a client practice, and partly because the number of individuals available to fill the roles is significantly reduced, lowering the barriers to entry. Being able to try new challenges with the safety net of having an established presence within a company facilitates moving outside a comfort zone. This is certainly not to say that everyone uses this flexibility, but it is an option that exists. All you have to do is grab the opportunity when it comes: in other words, Show Up.
My own move from international planning through tax accounting to becoming a technology professional was absolutely made possible by this ability to explore. I truly don’t believe I would have taken the leap of faith without the benefit of a hands-on test-drive. In my case, I ended up (re)discovering a true passion, and I ultimately made what started as an exploration permanent, moving back into client service as a technology professional. However, without having jumped at the opportunity, made possible by my in-house role, my risk-averse nature would never have allowed me to make such a drastic change.
So that is my story. It is certainly not one of the most interesting but rather serves as a teaser of what is to come. Going forward, we will explore many of the fascinating and diverse stories of the members of the Tax Bar, highlighting both the unique challenges overcome and profound successes realized by our colleagues.
And that leads me to the next phase since, to borrow a turn of phrase, “I don’t know half of you half as well as I should like!” With this introduction comes a request. If you know an individual whose story you would like to see told (perhaps even your own), let me know! Some of the most interesting, insightful, and inspiring histories are silently among us, hiding behind modesty, introversion, or competing priorities. Help me find these stories, bring them forward and share them. Please do not hesitate to reach out to me at Matt.Sontag@RSMUS.com with suggestions (or volunteers) for interviews. And, until next time, keep Showing Up! ■