VP - Funds Tax Lawyer, New York

This is an in-house tax advisory role, with strong technical and business exposure across the alternatvies funds platform. It is currently envisaged that the roleholder would be responsible for assisting in covering the following areas (although some flexibility may be possible depending on the roleholder’s experience, knowledge and interest):

• Private credit (direct lending / Mortgage securitization / CLOs)
• Hedge funds

The role involves:

• Providing hands-on tax support to the Alternatives business areas in the United States

• Assistance with new product launch tax work, including review of documentation and ongoing tax oversight for the fund ranges and vehicles associated with those businesses

• Oversight of documentation and tax due diligence on selected investments to be held by the funds

• Assistance in development of more robust tax-related processes and procedures, as the platform expands

• Working with the wider US Product Tax team (i.e., including non – Alternatives) on matters arising which impact the broader product offering

Key responsibilities

For the assigned Alternatives areas outlined above:

• Assist in the product tax work required for new product structuring and development

• Review tax structuring and documentation for new funds, SPVs and other investment vehicles

• Oversight of tax due diligence on investment acquisitions and review of tax provisions of transactional documents

• Support client relations and sales & marketing teams with client communications (including potential investors)

• Provide tax input in relation to tax provisions drafted in client side letters

• Liaise closely with members of the global Alternatives Product Tax Group responsible for covering the Alternatives areas above in their respective region (based in the US, EMEA and Asia Pac)

• Answer, or assist in the handling of, investor queries related to the taxation of the products associated with the Alternatives areas outlined above

• Assist with oversight of US tax reporting compliance work outsourced to external advisors

• Support Product Development teams in evaluating and developing new products with insightful and practical tax input

• Recognize enquiries and issues that relate to corporate tax, transfer pricing or VAT, and route these promptly to the appropriate wider tax team members

For assigned fund ranges:

• Advise on tax issues arising with new product launches

• Undertake necessary tax due diligence and setup needed for new launches, with support from team colleagues as required

• Monitor tax technical developments affecting these funds, and respond as necessary

• Maintain oversight of the tax operational processes that are necessary to support each fund

Skills and experience – required

The following are required from all candidates:

• Master’s Degree in Taxation, CPA, or JD

• Knowledge of tax aspects of hedge funds and private equity funds

• Understanding of fund and SPV structures for alternative investments

• Experience reviewing tax provisions of LPAs, PPMs, side letters and transactional documents such as credit agreements

• At least 3+ years experience in the investment management taxation industry with emphasis on alternative products.

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