I’ve always believed the best M&A tax partners are not number-crunchers; they’re architects. They understand how structure creates value, how legislation shapes outcomes, and how to make a transaction commercially work before it legally exists.
But building those teams inside law firms has become one of the toughest challenges in the modern legal market.
Bridging law and tax
Tax and law have always shared borders, but rarely a shared language. Many firms still treat tax as a support function, critical, but downstream. The top performers, though, have moved their tax capability upstream, integrating it into deal origination and capital structuring.
That shift sounds simple on paper, but the reality is cultural. Traditional corporate teams often move at deal speed; tax lawyers, by training, move at precision speed. The best M&A tax dealmakers do both, they’re commercial strategists who understand the client’s financial model, not just the clauses that paper it.
How the US firms approach it
US firms, for all their muscle, often struggle to embed front-end tax expertise. Their tax practices historically evolved around fund formation, restructuring, or disputes, valuable, but rarely transactional in the European sense.
When I speak with US managing partners, they almost all want “a tax partner who can sit at the table with the sponsors.” The problem is that there are very few who can. The skillset is niche, the market is tight, and the conflicts are constant. So the role often becomes reactive, not strategic, brought in after the term sheet, rather than shaping it.
It’s not a lack of intent; it’s a structural issue. Their economic models and practice integration make it hard for tax partners to own the client relationship in the same way a corporate or finance partner might.
The Magic Circle paradox
The Magic Circle firms, by contrast, have the depth and the pedigree, technically brilliant, globally aligned, and well-resourced. But they face a different constraint: price and leverage.
Their clients expect top-tier tax advice to be included in a fixed-fee M&A package, and that erodes the visibility of tax as a driver of value. Partners who want to lead strategically often find themselves boxed in by internal hierarchies that still treat tax as a specialist lane rather than a commercial one.
Many of those partners are now looking outward, to US platforms or to smaller, entrepreneurial firms where their practice can be monetised more directly.
The Big 4 and the blurred lines
Then there’s the Big 4. They’ve quietly become part of the front-end conversation. A decade ago, their role was post-deal diligence and integration. Now, the most senior Big 4 partners are advising on management equity, acquisition structuring, and even competitive bid support before the lawyers are instructed.
It’s impressive, but the crossover is limited. The regulatory barriers remain, and only a handful of those individuals could realistically integrate into a law-firm partnership. Still, their rise shows how commercial the tax function has become, and how law firms that fail to adapt risk being outflanked.
Value in the Tax Originators
The partners who can bridge all this, law, tax, and capital, are incredibly scarce. They need:
- Commercial instinct strong enough to hold their own with sponsors and CFOs
- Technical depth across multi-jurisdictional tax regimes
- The political agility to navigate law-firm hierarchies and client conflicts
There are perhaps a few dozen people globally who can do that at scale. Finding them is not recruitment, it’s headhunting at the surgical level.
Where Watson Reynolds fits in
This is the space where we operate most effectively. As a lateral headhunting advisory, Watson Reynolds doesn’t chase volume, we focus on alignment.
We advise firms that want to reposition tax as a front-end profit centre rather than a cost centre, and we identify partners who can deliver that shift. That means understanding not only the legal market, but the financial ecosystem, where the money flows, how it’s taxed, and who structures it.
Because we work across corporate, funds, and tax mandates, we have a panoramic view of where origination truly sits, and which platforms actually allow tax partners to lead, not follow.
The takeaway
The future of M&A tax isn’t in the fine print; it’s in the strategy room. The firms that will dominate are those that embed tax at the heart of dealmaking, not the margins of compliance.
And the partners who will shape that future are the ones who can translate between capital, law, and structure, the true dealmakers.
That’s the bridge Watson Reynolds helps firms build.