Tax Counsel – Asset Based Finance

Lead tax and structuring workstreams for Asset Based Finance (ABF) transactions, manage day-to-day transactional tax matters related to ABF investments, and coordinate with the ABF investment team, Core Platform, and external service providers. Develop and document Sixth Street’s preferred practices and tax positions, leveraging technology tools and AI to systematize processes and guidelines. Advise on tax considerations in ABF financings, including debt instrument characterization, loan origination and dealer considerations, REIT/REMIC qualifications, and securitization vehicle classifications. Manage exits, restructurings, and workouts of ABF investments; review transaction documentation; coordinate with external advisors on due diligence; drive deal execution and ensure tax reporting alignment with fund and investor covenants. Collaborate with stakeholders across the ABF business and Sixth Street, including Legal, Core, and Tax Reporting teams, to translate complex tax concepts into actionable guidance for the investment team. Maintain currency on changes to tax reporting laws and regulations and supervise outside counsel relationships. Requires licensed attorney with 6+ years of experience in ABF tax and related structured finance and securitization work.