Alternative Investments Tax Staff through Managers
$55,000–$250,000 year
On-siteNew York City, New York, United States or New York, United States
Job Summary
Research federal and international tax issues including debt to equity analysis, IRC 338(h)(10) elections, conduit financing, FDAP withholding, and derivatives taxation. Draft tax memos providing recommendations on these matters and advise leadership on transaction risks, mixed straddles, and unwinding structures. Actively develop processes for US Federal Foreign Bank Account Reporting (FBAR) filings and review relevant withholding tax treaties. Analyze tax treatment of derivatives, prepare matrices, and provide quantitative analysis on interest rate swap terminations and accounting method changes. Draft responses to Information Document Requests and collaborate with external tax advisors on project-specific matters.
Required Qualifications
- Research various federal and international tax issues
- Debt to equity analysis
- IRC 338(h)(10) election
- Conduit financing
- FDAP withholding
- Derivatives Taxation
- Draft various tax memos
- Provide recommendations on tax matters
- Advise functional leadership on tax risks and/or exposure
- Effect on mixed straddle transactions
- Unwinding of structures
- Derivative terminations
- US Federal Foreign Bank Account Reporting (FBAR) filing
- Research relevant treaties pertaining to withholding tax
- Review of tax elections in asset management systems
- Analysis of tax treatment of derivatives
- Quantitative analysis of tax effects
- Recommendation on accounting method change
- Work with external tax advisor
- Draft response to Information Document Request (IDRs)
- Transfer pricing effect on debt to equity analysis
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