Tax Advisor Vice President

Essential Job Functions

• Advise on tax aspects of fund formation, structuring and operation of private and retail investment funds, separately-managed accounts, and other transaction structures, including entity selection, jurisdiction considerations, and tax covenants and representations
  • Assist in negotiating side letters with investors and their counsel
  • Work with investors and their counsel to understand the client’s tax risk profile
• Advise on U.S. and cross-border tax aspects of primary, secondary, co-investment and direct transactions across private equity, real estate, infrastructure and private credit investment acquisitions and dispositions
  • Conduct and oversee tax due diligence to identify material tax risks, filing obligations, withholding exposure and other potential tax leakage
  • Evaluate and recommend investment structures based on investor profiles investment protocols and client-specific restrictions
  • Advise deal teams on tax risks, structuring alternatives, underwriting assumptions, and acquisition and exit considerations
  • Collaborate with internal and external legal teams to draft, review, and negotiate tax provisions in fund, subscription, side-letter, and transaction documents
  • Ensure 1446(f) compliance
• Instructing and managing external advisors in the completion of the above objectives
• Provide support to tax compliance and fund accounting teams to implement and administer executed investments and fund structures
• Assist in the maintenance of the existing database of client tax information and implementation of new technologies to enhance investment process
• Support legal teams in completing investment subscription materials for fund-of-fund investments
• Support the tax compliance team on tax withholding determinations, W-form production and review, entity-classifications and FATCA classifications and other post-closing requirements
• As requested, assist investors and their advisors with tax questions and refund claims
• Monitor and advise on potential impacts of tax legislative, regulatory and market developments
• Provide tax training sessions for various teams, as appropriate

Education and/or Work Experience Requirements

• JD required
• Licensed in good standing
• 3-6 years of tax-focused private investment fund experience at a nationally recognized law firm. In-house experience, a plus.

Required Knowledge, Skills, and Abilities

• Working knowledge of U.S. tax rules on “effectively connected income,” “commercial activity income” and “unrelated business taxable income”
• Knowledge of entity classification and investment fund market practices on tax issues
• Effective communication and resolution-oriented negotiation skills
• Ability to prioritize and manage multiple projects, working with direction from senior team members
• Ability to explain complex tax concepts to non-tax professionals

Salary Range: $215,000 - $227,500

The salary range is an estimate of pay for this position.  Actual pay may vary depending on job-related factors that can include location, education, skill, and experience.  The salary range does not include any benefits or other forms of possible compensation that may be available to employees.