A well respected Financial Services Tax practice is sourcing for a high calibre individual to join its growing team. This is ideal for a person looking to specialise in the Private Equity/Alternative Investment market.
As a Senior member of the team you will
* Manage a portfolio of clients, primarily mid-market private equity funds and their executives & hedge funds.
* Give UK and international tax advice on appropriate private equity and credit fund structures, considering the tax residency and location of the investors and managers and the nature of the underlying investments.
* Offer International tax advice, including advice on the prevention of UK permanent establishments (including the application of the Investment Manager Exemption), the application of the controlled foreign company rules, the application of the diverted profits tax legislation, the application of the hybrid and other mismatch provisions, the corporate interest restriction to name a few.
* Give deal structuring advice including preparation of tax steps papers, funds flow and exit strategies.
* Design of commercial and tax efficient structures for private equity investors and the portfolio company management teams, including the design and implementation of equity reward plans.
* Advice on carried interest arrangements, including income based carried interest rules and the provisions applying to disguised investment management fees.
* Tax due diligence (both buy-side and sell-side) primarily within financial services (alternative lending and asset management).
* Structuring advice with respect to the dissolution of fund structures and implications for the limited partners and carry members.
The employer in question is happy for a person to learn the nuisances of this market whilst gaining access to an incredibly broad advisory role.
Please call Una Ward for a confidential conversation.