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New York City office of our client seeks tax attorney with 4 years of experience. The candidate will provide US tax advice to multi-national corporations on sophisticated cross-border tax issues, as well as high-net worth individuals and families in their personal business endeavors. Must preferably have LL.M. degree. Must be admitted to, and in good standing with the State Bar of Connecticut and/or New York. Experience working on a variety of closely held company, investment and joint venture matters, including corporate governance matters and transactions (real estate, mergers and acquisitions, private equity and fund work) on either the buyer or seller side, manager or investor side is required. Experience drafting partnership and operating agreements and associated governance documents is a plus. Substantive experience advising clients in diverse tax issues, including integrated federal, state, international, estate and gift taxes is essential. Experience with insurance, financial products, and taxation of compensation arrangements is a plus. Experience with international cross-border tax structuring (inbound and outbound, including working knowledge of Subpart F, PFIC, permanent establishment, tax treaties and other significant tax areas) is needed. Other areas of interest include: Reference to "limitation on benefits tests" in connection with treaties; Inbound and outbound US federal and state nexus and "doing business" issues; Debt obligations, promissory notes, debt/equity analysis, and financial instruments; Familiarity with fund structures (private equity, venture, hedge, real estate) and associated taxation.
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