Overview
Our client is a leading global private investment firm.
Responsibilities
- Advise on U.S. and international tax matters related to fund formation, structuring, and ongoing operations.
- Design and implement tax-efficient structures for cross-border investments.
- Conduct detailed U.S. tax treaty analysis, including application of limitation on benefits provisions.
- Provide advice on Section 892 issues and structure investments for sovereign and foreign government investors.
- Review and negotiate fund documentation, side letters, investment agreements, and financing arrangements.
- Work closely with internal teams and external advisors to implement and operate investment structures.
- Support tax due diligence and post-acquisition integration of portfolio companies.
- Advise on debt financing and capital markets transactions from a tax perspective.
- Monitor global tax developments and evaluate their impact on the firm’s investment strategies.
- Full-time, permanent position based in Montreal.
- Occasional travel to New York expected.
- Collaborate with an international tax team.
- The work environment is collaborative, demanding, and globally integrated, with a lean and professional team culture.
- Competitive compensation.
Qualifications
- JD and LL.M. in Taxation.
- Minimum of 2 years of experience in U.S. tax law, ideally at a top-tier law firm.
- Strong command of U.S. federal income taxation, including partnership, corporate, and international tax.
- Demonstrated experience in private equity fund structuring and transactional tax support.
- Familiarity with U.S. fund market terms, side letters, and cross-border structures.
- Excellent drafting, analytical, and negotiation skills.
- Proven ability to manage multiple priorities in a fast-paced, international setting.
- Fluency in English is required; French is a plus.
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