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November 15, 2007
International Tax Guest Blogger
Periodically throughout the year the CSO will be posting blog entries from guest bloggers about various topics. Please note that the views expressed by our guest bloggers are the personal opinion of each blogger and are not necessarily the views and opinions of the CSO. The CSO guest blogger entries are intended as an opportunity for attorneys currently practicing in the legal field to share their insight and advice with law students.
To conclude International Law Theme Week, our third guest blogger of the year, Charles Hong (class of 2002), shares his advice on choosing a career in international tax.
Choosing a Career in International Tax
By Charles Hong, Class of 2002
Like many of you, I had little idea of what international tax entailed while in law school. All I knew was that I enjoyed tax and wanted to pursue a career in Tax law (this after taking Professor Jensen's Federal Income Tax Course (which I recommend for anyone interested in Tax law)). I learned about international tax while earning my LLM. After taking an international tax course, I developed a strong interest and desire to practice international tax. Not only was the subject matter interesting (if you're the type of person who finds tax interesting) but I also felt the need for international tax practitioners would increase over time with economic globalization.
And to some degree, it's been true. With economic globalization, foreign investments have increased significantly. Accordingly, international tax practitioners are asked to analyze or assist in creating and implementing global business structures. Thus as an international tax practitioner, one often utilizes the advantages of various non-US tax regimes for the benefit of the client in creating and implementing these investment structures. All the while, we have to be mindful of the US tax rules and how the foreign investment structure will be treated from a US tax law perspective. As a result, there is this constant balancing act that a tax practitioner must perform in advising on any foreign investment structure. However, a tax practitioner's job doesn't necessarily end with structuring a foreign investment.
At the end of the day tax is about numbers (i.e. dollars) and so it is also important that a tax practitioner can work with numbers. But in addition to being able to work in numbers, one has to be able to explain and interpret these numbers in the context of US and foreign tax law but more importantly the numbers need to make sense from a business perspective. And this combination is also what makes international tax (and tax in general) so complex and interesting. But it's this exercise, in my opinion, that really helps an international tax practitioner learn and apply the rules.
For those readers who are still interested in international tax after reading this, I have one last comment to make. You have to enjoy tax. The issues and topics can be esoteric and nebulous and unless you're willing to work at it, it can be very mind numbing. Tax isn't very glamorous. Often times, you will find yourself working quietly at your desk researching and reading. And it may require looking over a large set of materials before finding an answer that might take only a few sentences to write. You may also find yourself reviewing tax returns and calculations when analyzing a transaction or addressing a client's question.
As for starting a career in international tax, it is important to know that not many firms have an exclusive international tax practice. You may be asked to be a general tax practitioner and over time develop an expertise in international tax. And if are able to join a firm with an international tax department, you may have to spend some time learning domestic tax before getting to specialize in international tax. However, if you can join an international tax department directly out of school, definitely consider it. In addition, some of you should consider accounting firms to begin your career. Although there are some drawbacks, it does provide a setting to get some real good international tax experience.
And one last misconception I want to clear up for those considering international tax, is that by practicing international tax doesn't necessarily mean that you will be traveling around the world discussing business transactions. Initially, you may log more frequent flyer miles traveling to get a cup of coffee during the middle of your day then flying to another country. So international tax is not like joining the Navy--if you know what I mean.
Lastly, if you're STILL interested in practicing tax law after reading this, you should also visit with the tax professors at Case. They are all great resources. And if you happen to visit Professor Jensen be sure to talk about the Cleveland Indians but don't talk about game 7 of this year's ALCS.
Posted by kcc17 at November 15, 2007 04:53 PM