A global private markets asset manager with more than $40 billion in assets under management is looking for a Head of Tax Structuring. The Firm's powerful global platform offers clients investment opportunities through primary fund investments, secondary investments, and direct co-investments in co-mingled funds or separately managed accounts.
Responsibilities for multijurisdictional tax planning, structuring and implementation for the Firm's global investment business. This includes tax structuring for the management company, its operating affiliates, funds, separate accounts and other offerings sponsored by the Firm. Incumbent will also be responsible for supporting global investment teams tax due diligence and structuring efforts. Incumbent will work with senior management to plan and execute an expansion of the structuring function as required to support the Firm's strategic plans.
Job Skills and Abilities
* Comprehensive knowledge of US taxation and demonstrated experience in areas of taxation applicable to private investment funds /managers including but not limited to:
o Global group income tax planning including transfer pricing, repatriation, VAT/HST and similar taxes
o Individual tax matters pertaining to participation in investment partnerships (GP/Carry Vehicles) and trading partnership
o UBTI, ECI and FDAP taxes and structures used to mitigate the same
o Tax considerations specific to equity, debt/credit and real asset investments
o Ideal candidate would also have, or be qualified to quickly develop, a working knowledge of these topics in other jurisdictions in which the firm operates
* Familiarity with common investment holding company structures used to mitigate tax, filing obligations or other structural impediments in investment assets.
* Familiarity with common European fund structures
* Excellent analytic and communication skills including the ability to communicate complex technical tax analysis in layman's terms and to support the "operationalization" of complex cross jurisdictional structures for both investment entities and management company affiliates.
* High personal integrity and considerable experience building effective interpersonal relationships with stakeholders.
Support for investment due diligence/structuring:
* Participate in investment team weekly forums for high level issue spotting
* Coordination and oversight, along with members of legal team, of external legal/ accounting professionals performing tax due diligence activities for investments
* Ensure that reporting issues identified during due diligence are communicated and coordinated with tax compliance team
* Make recommendations to senior management for blockers, aggregators, or other holdcos required for tax mitigation, assist with set up of same including communication to tax compliance and other operational teams responsible for ongoing administration
Tax structuring for funds, custom solutions and other offerings:
* Participate in product/solution development efforts with a view towards creating structures that address tax considerations for all relevant stakeholders.
* Provide tax support for Investment Relations team during fund launch and closing process
Support for Management Company:
* General tax structuring support for the global management company group
* Support all tax aspects related to offices in new jurisdictions
* Analyze impact of tax law changes relevant to any area of the business, recommend and support execution of any required changes
BA/BS. If degree is not in accounting or tax, candidate must have demonstrated experience in these areas. JD/LLM/MST
Minimum of 15 years of tax experience gained at major accounting or law firm or combination of accounting/law firm and in-house. Must be US licensed attorney or CPA in good standing.