Associate Tax Counsel (New York) – $30B AUM Private Equity Fund

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Summary

Responsibilities: Successful candidate will assist with all tax planning and structuring for numerous Funds, 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… >>>


Company Information:

$30B AUM Private Equity Fund


Job Description:

Responsibilities:

Successful candidate will assist with all tax planning and structuring for numerous Funds, 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.
  • 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:

 

Required Background:

 

  • Law degree and approximately 3-5 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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