In big firms, this work divides up into federal and state/local tax. State/local tax attorneys tend to work more on litigation issues (mostly people seeking refunds or appealing an assessment).

Federal tax attorneys divide up into tax controversy (audit and litigation support) and transactional. The federal transactional practice varies by firm and can include cross-border transactions, M&A support, REITs, mutual fund work, etc.



These attorneys do not handle tax returns for companies and individuals. Those are usually done by accounting firms. This is a very complex, regulation and rule-driven practice.

There are many state-by-state differences and the federal law changes all the time.

There is a heavy burden to keep with current developments (daily). Day-to-day work for tax controversy or state tax practice is similar to litigation. For federal transactional, there is a lot of research (more than in most practices), drafting of memoranda, and reviewing documents from other departments.

An LL.M. is strongly recommended for someone who wants to seriously pursue this practice.

It’s a service practice to other departments and theirs tends to be a smaller department.