US Tax Senior Manager - Zurich - Private Equity

An unique opportunity has arisen to work with the leading Partner for many of Switzerland’s largest asset managers, banking groups, pension funds, insurance companies, family offices, and sovereign investors.

You will join as Senior manager at a pivotal time of growth for the team. You will have extensive knowledge of US tax rules regarding alternative investment funds, fund of funds structures, US inbound transactional tax matters, particularly secondaries and co-investments, and operational and compliance tax matters.

The immediate focus on this role is to ensure, the team, operating model and compliance review process aligns to the standards the client base expects. This is role is ideal for a US Tax compliance SME who over time would like to focus on Tax planning and M&A Tax.

You will review and analyse financial data, prepare and file tax returns, and assist businesses in meeting their tax obligations while minimising risks of non-compliance. You will be pivotal in sustaining a high performing, diverse, and inclusive team.

Over time, you will work with the Partner to design cross-border private equity, private debt, real estate, and infrastructure fund structures to minimize US and EU tax leakage and investor tax filing obligations, such as avoiding ECI, FIRPTA, CAI and UBTI.
You will develop a deep experience in Section 1446(f) withholding taxes on the disposition of partnership interests, aid Swiss investor-alternative investments sell-side project through complex Section 1446(f) and FIRPTA issues. Conduct treaty eligibility analysis and design structures to maintain treaty eligibility while blocking US tax obligations, e.g., by using reverse hybrid intermediaries. Work closely with Swiss and EU tax experts to ensure investments do not trigger non-US tax problems. Work regularly with Luxembourg, Irish, Cayman, Delaware and Singapore fund platforms, as well as Swiss investment vehicles such as investment foundations and single investor funds. Serve as the tax expert during audits, testing alternative fund deals for tax efficiency and filing obligation risks.

Successful completion of Qualification as a U.S. Certified Public Accountant, IRS Enrolled Agent, or member of the Bar of one of the jurisdictions of the US required;
Extensive knowledge of U.S. tax compliance and consulting needs of financial services clients, including expertise in tax compliance software.

As a priority this role will only accept Swiss Work Permit B, or a Swiss Work Permit C are allowed to be included, plus of course any CH/EU/EFTA nationals allowed. Due to time allowed, full sponsorship is not available at this time.

This role is being supported via CH Port for effective management of a thorough and efficient process.

This is just superb opportunity to access a career enhancing role as the market in Switzerland starts to move.