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.

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