The global liquidity crisis of the last two years has produced such a volatile, and at times unprecedented, setting for business, that the predictions of even the most learned commentators have been wildly incorrect.
What does this spell for the tax recruitment market? When Eddie George addressed Pure's CFO dinner in January 2008, he informed us that the crisis 'in the US banking system' was not systemic and unlikely to have a profound effect on a robust UK economy.
Back in January 2008 a senior banker advised us to work through the pending economic downturn by 'partnering closely with world-class businesses'.
He recommended Lehman and Bear Sterns.
Pessimism has unfortunately been the most accurate recent wisdom.
But what is the market telling us about 2010 trends in tax? Are the green shoots going to be nourished or scorched? I shall seek here to identify trends that have become sufficiently established for them to achieve consensus that they will feature throughout 2010.
Bad news first With budgets and headcount plans largely in place for 2010, the resulting picture is one of slow growth and institutions targeting wins in market share rather than absorbing market growth.
With the exception of the banking industry, and a small number of distressed professional service firms, headcount reductions in UK tax have been minimal.
Combining this with modest growth plans means that roles and career opportunities in tax look set to remain limited in the coming year.
The financial services sector has demonstrated that it can either underpin or undermine the UK global economy.
But a substantive recovery will require improvements in liquidity, sentiment and mainstream corporate activity, along with a return to health of the cash-cow areas of M&A, private equity and real estate.
Of these only the most fragile, sentiment, has shown a promising upward trend; for now.
M&A has shown some signs of a sustainable market upswing, but is a long way off a respectable volume.
Professional services firms by necessity have many of the same dependencies affecting their fee income.
Advisers have also borne the brunt of a sustained downward push on pricing.
Opportunities will therefore be limited.
The supply of candidates still outweighs demand.
Yet an exaggeration of this perception has led some employers to raise the bar above the level of the candidate pool at a time when the top 10% of candidates are being more closely protected by their institutions than ever before.
Of course skilled tax professionals still continue to make career-enhancing moves.
Moreover, our clients who choose to take advantage have been able to make extraordinarily good hires.
But these processes are competitive and challenging: 'The right talent for the right times.
' Everyone needs to remain realistic for 2010.
Those between jobs may need to consider more seriously the merits of interim and interim-to-permanent solutions.
Those currently employed need to take very good advice.
Often our advice is that you should stay put.
More suitable options will come along.
The best time to consider your options is always when you don't absolutely need to.
So where's the good news? Volatility and change create opportunity.
So does regulation.
Businesses have now largely put in place the mechanisms to adapt to a prolonged downturn.
These have various implications for tax, some of which require an increase in the nature and value of the tax treatment and the role of the tax practitioners.
Corporate governance, a greater focus on risk management, requirements for improved liquidity, the decentralisation and migration of multinationals and the push-pull of in-sourcing versus outsourcing all have tax and personnel implications.
The greatest need as the market picks up will be where people have cut back too far on staff numbers.
So amid the downturn there are new roles and revenues to be won.
VAT is a real-time tax, collected and paid at source.
Given the heightened demand for liquidity among corporates, any mechanism that so directly impacts on cashflow is bound to come to prominence.
VAT planning is in demand.
VAT projects, systems implementation and international VAT planning can materially affect cashflow.
VAT compliance and risk requirement meanwhile change with each new wave of legislation and regulation.
Opportunities for VAT practitioners in-house, for interim VAT project leaders and a modest growth in Big Four VAT practices were a feature of Q3 and Q4 2009, and they look set to continue.
Transfer pricing and supply-chain management experts were the most sought-after people commodity in 2009.
Multinationals account for 60% of world trade.
National authorities worldwide have increased the challenges to transfer pricing regimes and the penalties for any breach.
Previously benign TP regimes such as Spain have made tackling TP systems a core objective.
Supply chains continue to expand in geography and complexity.
The benefits of getting transfer pricing right and the penalties of miscalculation are huge.
It is no surprise then that two of the Big Four posted revenue growth from their transfer pricing teams at 32% and 28% respectively.
Should I stay or should I go now? Migration of multinationals from high to low tax jurisdictions has been a high-profile feature of the credit crunch.
Tyco and Yahoo relocated to Switzerland's lower tax regime, and Guy Hands and other tycoons moved offshore.
This creates a deficit in the UK and opportunity overseas.
The UK is still seen as the centre of international tax expertise par excellence.
So it is no surprise that big roles in locations including Zurich, Qatar, Moscow, Hong Kong and Paris have been taken by UK tax practitioners.
The ratio of the number of tax practitioners moving in-house from advisory firms in continental Europe is about 15 years behind the UK - but rapidly catching up.
The growth in the number of international tax opportunities in-house is the largest upward trend among our clients.
Decentralisation among US multinationals for UK-based tax teams to tax experts based with the business in each key jurisdiction add to this traffic.
This looks set to be a long-term phenomenon.
Happily, UK tax practitioners who are willing to relocate can take advantage of this.
Professional services firms bear the brunt of a downturn on reductions in transaction volumes and advisory fees.
Law firms have been particularly exposed.
Unlike an accountancy practice they cannot have a stable flow of revenue from audit and compliance.
Nor do they have big countercyclical insolvency and restructuring practices.
Those heavily hedged towards investment banking, M&A and real estate have suffered.
But they have also adapted.
Tax litigation has been a significant growth area.
It has married very well with the general increment in litigation and dispute resolution among the firms.
A number of law firms have for the first time demonstrated an interest in jumping on the transfer pricing bandwagon.
Hiring partners or teams with a revenue following is a feature that is unlikely to change.
The accountancy firms have lost revenue in M&A and real estate but made up ground in specialist taxes and areas such as restructuring.
A big question for 2010 will be how the larger firms adapt to service the needs of multinationals across borders.
2009 saw each of the Big Four take a different approach to attempting to work to the global, rather than national, client base.
For those who get it right in 2010, the prize is enormous.
Heads of tax are frustrated by multiple account teams and relationships, and crave a global service level that reflects their business.
A genuine cross-border professional service firm can also facilitate cross-border tax effective solutions and services.
Some firms are divided by geography, others by service line.
It will be fascinating to see who the end users, heads of tax and CFOs consider to be the best at delivering multinational service.
She loves me, she loves me not It will also be interesting to observe the 'she loves me, she loves me not' dynamic between law and accountancy firms.
Arguably the biggest wins of 2009 - the Lehman insolvency and the Lloyds-HBOS merger - were won by Big Four and magic circle firms acting in cooperation.
Yet the demand for revenue has led the firms to encroach on each others' traditional territories.
The Big Four have all started building tax litigation practices as the law firms move in to transfer pricing.
2010 could see a few more allegiances won and lost.
So what of financial services, the focus of hope and despair in this downturn? With liquidity constraints have come headcount restraints.
Some institutions are now more favourable locations for interim tax specialists.
But where headcount is freed up, tax opportunities could be surprisingly abundant.
Banks are embracing new levels of corporate governance and risk control.
Tax risk management of the front office and the institutions' international framework is viewed as an essential part of building an adequate control function.
In the last two quarters of 2009, the financial service sector was the biggest hirer of all inhouse areas.
Delivering the correct advice and structures to business units, and a compliant international operations structure, is vital.
The fact that a number of banks are coming back to profit and intend to use headcount for risk control bodes well for 2010.
Summary The tax profession is a long way from the halcyon days of 2007.
But in terms of opportunity there are sufficient legislative, commercial and geographical dynamics to create roles and challenges for many tax specialists.
The areas that should thrive are VAT, TP and employee solutions.
I also predict increased hiring in the international arena and our beloved banking sector.