Tax Structuring VP - NYC Asset Management

Roles and Responsibilities
The successful candidate will provide tax advice throughout the deal life cycle, including:

• Tax structuring for US distressed assets, real estate, and structured products, including loan origination and structured equity transactions.
• Federal and state tax modeling.
• Tax due diligence for buy-side transactions.
• Input on tax-related aspects of legal documents (e.g., Sale and Purchase, Facility, Shareholder Agreements).
• US tax research and planning for existing domestic and international deals.
• Transfer pricing planning and defense.
• Analysis and application of tax treaties.
• Advising on tax implications during restructurings (including debt-for-equity swaps).
• Exit planning, including vendor due diligence and exit analysis refresh.

Qualifications
The ideal candidate will have 7-10 years of tax experience, with:

• Relevant tax qualifications (e.g., JD, LLM, or MS in Tax).
• A background in Big Four federal or international tax.
• Ability to provide practical, commercial tax advice.
• Strong knowledge of US ECI, UBTI, CODI, and FIRPTA provisions.
• Experience in international tax planning (e.g., CFC, PFIC, GILTI, FTC, US CTB elections).
• Excellent written and verbal communication skills, with the ability to distill complex tax analysis into clear insights.
• Strong organizational skills and attention to detail.
• Adaptability and a positive demeanor.
• Proven ability to develop and maintain solid working relationships across teams.