Associate Tax Counsel

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Summary

Successful candidate will Assist with all tax planning and structuring for over 14 Funds, 5 CLOs, SPV’s, and managed accounts. Funds involve master feeder structures, mini-master structures, and side-by side structures.   Funds primarily invest in fixed income securities, but also invest in public equity, private equity, derivatives, currencies, swaps, commodities and real estate. Specific responsibilities… >>>


Company Information:

This company is an employee owned, global asset management firm that specializes in opportunities across the credit universe in sectors such as high yield bonds, leveraged loans, distressed debt, structured products, emerging markets, private equity and credit-themed equities.


Job Description:

Successful candidate will Assist with all tax planning and structuring for over 14 Funds, 5 CLOs, SPV’s, and managed accounts. Funds involve master feeder structures, mini-master structures, and side-by side structures.   Funds primarily invest in fixed income securities, but also invest in public equity, private equity, derivatives, currencies, swaps, commodities and real estate.

Specific responsibilities are as follows:

  • Assist with reviewing investments, workouts, restructurings and structuring transactions relating to a number of global funds and a number of managed accounts to ensure maximum tax efficiency.
  • Actively implement U.S. tax guidelines intended to mitigate adverse U.S. taxation of offshore funds, foreign investors and tax exempts.  Identify improvements to guidelines given market developments.
  • Help with providing oversight of adherence to U.S. tax guidelines checklists and subsequent development of such checklists.
  • Research issues relating to withholding taxes, tax treaties, foreign tax minimization, effectively connected income, FIRPTA, PFIC, CFC, and miscellaneous partnership and C corporation tax issues.
  • Assist with ensuring that policies and procedures concerning documentation of transactions are established and implemented.  This would also include historic review and updating of files.
  • Assist with review and drafting of internal restructuring, fund setup, and existing fund documents, and work with outside legal counsel and accounting firms as needed.
  • Keep track of and update tax department regarding pertinent tax law developments.
  • Research issues related to client service/investor requests.
  • Assist with researching tax compliance related issues.

Requirements / Qualifications:
  • Law degree and 4 plus years of prior experience handling tax transactions and financial instruments in the hedge fund space – with focus on credit.
  • Excellent written and verbal communication skills.
  • Strong team player, willing to work in a collegial environment.
  • Excellent organizational skills; ability to handle multiple tasks simultaneously under demanding timeframes.

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