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• Tax Law

• • Overview

  • A Day in the Life of

  Put Simply...

  Tax law forms an important ingredient of literally every commercial, corporate or personal transaction, since it appears that every facet and segment of life today is taxed. It is a big source of revenue for authorities and its subject-matter is voluminous and complex.
  
  You must always be up-to-date with changes in government legislation which undergoes changes every year. Tax law involves contentious and non-contentious work and is a crossover service which is associated with almost all other practice areas, be it corporate or commercial or real estate, regulatory compliance, retail goods and services, etc.
  
  Most firms have a separate tax department and activity can intermingle with other practice areas. This is a particularly lucrative area for solicitors, as good advice can often result in clients saving literally millions of pounds.

  What is involved in Tax Law?

  Tax lawyers are required in both private and public domains. A private sector tax practitioner’s workload will cover various core areas, normally focusing on the best way to structure assets, assisting with various documentation and negotiations on transactions and jockeying the deal to completion.
  
  You will have to advise clients on the implications of tax during transactions, especially when structuring financial and administrative frameworks in different markets.
  Contentious tax matters will include filing claims on behalf of clients or defending them under cases brought by governmental and enforcement authorities. This will also involve drafting appeals for tax relief and contending against unfair tax provisions.
  
  Tax lawyers in the public sector will work for governmental tax and revenue departments, tax statutory bodies and panels. Their work will include investigating tax evasions, auditing tax accounts of companies, prosecuting tax offenders, assisting in interpretation of tax rules and regulations and defending public authorities against private sector claims.
  
  Much of a tax solicitor’s work today covers what earlier used to be the domain of accounting firms. More and more clients are looking for professionals who combine legal and accounting principles’ expertise to ensure uniformity and quality of advice received.

  What is needed for Tax Law?

  Tax law can be very complex and confusing, hence a very strong background in academic excellence is a must. Tax solicitors require exceptional skills in analysis and reviewing, communication and negotiation and are in a position to minutely scrutinize and study business structures and constitutions to provide clients with the best and correct advice.
  Extra qualifications in accounting matters will be an added advantage. Clients will be very interested in getting all their business advice in one shop, and tax being an integral part of business transactions, it makes sense to have all-round knowledge.
  
  The job involves a lot of study and research so it is important to have an intellectual approach and pay great attention to even the minute details.

  Current Climate for Tax Law

  The volume of corporate finance and capital market deals have grown humongously and these have a significant tax exposure component, making tax law a very attractive and lucrative practice area.
  
  Clients now expect their law firms to also act as accountants on occasions. As such, many departments at law firms are now looking for bolster their accounting credentials by way of boosting their client rosters.
  
  

  A day in the life of... a Corporate Tax trainee at Berwin Leighton Paisner

  I typically try and get in to work with enough time to have some fruit and fibre and read the main news stories before my day begins in earnest.  Of particular interest and importance is knowing, in great detail, why my football team (Spurs) lost again last night!  Having finished my breakfast, I make my may to the Corporate Tax workgroup meeting.

  In the Corporate Tax department we have a weekly group meeting in which all manner of things are dealt with.  Today we have two members from our marketing team with us to discuss marketing initiatives and strategies, which is something BLP encourages its junior lawyers to get involved in from the outset.

  After the meeting I continue with an extensive research task I have been given by one of the partners.  For my first time in the department, I am looking at what are known as secondary tax liabilities.  Secondary liabilities are, in essence, where a company is liable to HM Revenue & Customs for the unpaid taxes of another company connected with it in some way.  I have been charged with analysing whether or not a company set up to issue bonds to the market may be liable to such secondary tax liabilities. 

  When I was asked to look into this area I felt a little daunted.  However, one of the best things about the Corporate Tax department (and BLP in general) is the collegiate atmosphere and approach to work.  What this means in practice is that I felt comfortable talking to a number of partners and associates about helpful sources of learning on the subject.

  As interesting as the research is, my stomach dictates that by 12.30 I make my way down to BLP’s staff restaurant with the other trainees in my department.  Today I decide to go with the Lamb Rogan Josh on offer and sit down to catch up with any gossip or discuss plans for Friday night.  Having eaten my recommended daily calorie intake, I make my way across to training.

  Today one of the senior partners is running a training session for the junior members of the Corporate Tax department on methods through which non-residents can invest in UK real estate.  The session is particularly useful and interesting because it is aimed at my level and is interactive.  Given the technical nature of the subject, we receiving regular training in Corporate Tax!

  After training, I begin drafting a side letter to a Tax Deed of Covenant on a transaction I have been heavily involved in from the beginning of my seat.  One of the associates gives me a precedent to work from and I tailor the provisions to reflect the current deal and the wishes of the client.  Once I have finished drafting the letter (and have read it through twice!), I give it to the supervising partner to look at.  As she reads through the letter we discuss why certain provisions have been drafted as they are. With (thankfully) minimal amendments, I send the letter to the solicitors acting for the party opposite our client.

  Having continued for a while with my secondary tax research, I then decide to prepare for a conference call at 17.30.  The conference call is with my supervising partner and a few members of the Corporate Finance team.  On the call the tax implications of different ways of establishing an investment fund are discussed with the client, as well as a number of commercial and practical points.  Though I have not been told to make an attendance note, I jot down the salient points discussed so that I can refer to these at a later date.

  Back at my desk I check my emails and then help my supervisor with a quick research task that requires finding HM Revenue & Custom materials.  As nothing else is urgent, I decide to call it a day.  I am off to the gym tonight.  I play football and rugby for BLP (when my knee permits) and am never adverse to a trip to the pub after work.  BLP is genuinely a social place to work and there are always a lot of faces in the regular haunt on a Friday night.

  Daily Diary

  Time:	Diary entry
  08:45	Check emails and the BBC news whilst eating my breakfast.
  09:00	Weekly Corporate Tax group meeting.
  10:00	Research on secondary tax liabilities in the context of a securitisation vehicle.
  12:30	Quick lunch with other trainees in the department.
  13:00	Training on methods through which non-residents can invest in UK real estate.
  14:00	Drafting a side letter to a Tax Deed of Covenant on Project Confidential.
  15:30	Discussing issues relating to the side letter with partner and sending side letter to other side’s solicitors.
  16:00	Continuing research on secondary tax liabilities.
  17:00	Preparatory reading for a conference call.
  17:30	Conference call with Corporate and the client on the tax implications of establishing an investment fund to be managed by a major bank.
  19:00	Check emails and help my supervisor with a quick research task.
  20:00	Walk across London Bridge to catch the train home.

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